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DEPArTMEnT of EDucATion, TrAininG AnD EmploymEnT
Queensland VET Sector
International Education
Agent Management
A Best Practice Guide for
Agent Management

           Department of Education, Training and Employment
                            Queensland Government Australia
TAFE Queensland international
Department of Education, Training and Employment
Education House
30 Mary Street
Brisbane Qld 4000

PO Box 15033
City East Qld 4002

EmAil: TAFEQueenslandinternational@deta.qld.gov.au

WEB: http://training.qld.gov.au/international

December 2011
Queensland VET Sector
International Education
Agent Management

       International Education: Best Practice Guide Series



       Department of Education, Training and Employment
                      Queensland Government, Australia
Acknowledgments
    The International Education Agent Management Best Practice Guide (the ‘Guide’) has been developed by
    the International Education Resources Group for the Queensland Department of Education, Training and
    Employment. Copies of the Guide and associated resources are available on the Queensland Department
    of Education, Training and Employment website at http://training.qld.gov.au/information/tafe-qld-
    international/best-practice-guides.html.

    Requests for Information
    This Guide contains ideas and examples of recognised industry good practice in international education
    agent management. It has been developed in good faith to support the Queensland VET sector and is
    intended for use as a source of ideas and options that can be adapted and customised for a provider’s
    unique situation. The Queensland Government disclaims all responsibility and all liability for any expenses,
    losses, damages and costs you might incur as a result of the information in this Guide being inaccurate or
    incomplete in any way, or from the use of, or reliance on, this material.

    Disclaimer
    By their very nature, Best Practice Guides are a work in progress. They are a snapshot in time of how
    providers are dealing with a topic and/or market opportunity. It is not possible to capture every detail
    regarding the subject or every provider’s experience. As a dynamic industry resource your ongoing
    submissions, contributions and ideas are welcomed – please email us at TAFEQueenslandinternational@
    deta.qld.gov.au.




2    International Education Agent Management | A Best Practice Guide
Industry Contributions
TAFE Queensland International wishes to acknowledge the valuable insight of the registered training
organisations (RTOs), education agents and other industry experts in Queensland that provided input into
this Guide. These include:
 •	 AMET Education
 •	 AusEd Brisbane
 •	 Australian Council for Private Education and Training (ACPET)
 •	 CHARLTON BROWN®
 •	 City Smart Education
 •	 Gold Coast Institute of TAFE
 •	 IDP Brisbane
 •	 International Education Services (IES)
 •	 Marlin Overseas Student Agency
 •	 Metropolitan South Institute of TAFE
 •	 Migration Institute of Australia
 •	 Queensland Education and Training International (QETI) (now known as International Education and
    Training Unit within the Department of Employment, Economic Development and Innovation (DEEDI))
 •	 Sarina Russo Schools Australia
 •	 Shafston
 •	 Southbank Institute of Technology
 •	 Think Education Group
 •	 Viva College




                                                International Education Agent Management | A Best Practice Guide   3
Table of Contents
       Acknowledgments 	                                                       2
       Requests for Information 	                                              2
       Disclaimer 	                                                            2

    SECTION ONE: AGENTS AND THE AUSTRALIAN INTERNATIONAL EDUCATION SECTOR 	   6
    1.	 Introduction		                                                         7
       1.1.	 Aim of the Guide	                                                 7
       1.2.	 The Approach 	                                                   8
       1.3.	 How to Use this Guide 	                                          8
    2.	 What is an International Education Agent?		                           8
       2.1.	 Types of International Education Agents 	                        9
    3.	 Why Use an International Education Agent?		                           10
       3.1.	 Reasons to Partner with International Education Agents	          10
       3.2.	 Reasons not to Partner with International Education Agents	      10
    4.	 Agent Regulation and Control 		                                       11
       4.1.	 ESOS Act and the National Code 	                                 11
       4.2.	 Education Agents Peak Professional Body	                         13
       4.3.	 Additional References and Resources	                             14
    5.	 Managing Agents in Turbulent Times 		                                 14
       5.1.	 Potential Risks 	                                                15
       5.2.	 Due Diligence and Monitoring 	                                   16
       5.3.	 Managing Change Effectively 	                                    16
    6.	 Strategically Managing Your Business		                                18

    SECTION TWO: THE AGENT MANAGEMENT PROCESS 		                              19
    1.	 Best Practice in Agent Management 		                                  19
       1.1.	 Steps in Agent Management 	                                      19
    2.	 Identifying Agents		                                                  20
       2.1.	 Market Alignment	                                                20
       2.2.	 Agent Alignment	                                                 21
       2.3.	 Sources of Agent Contacts 	                                      23
    3.	 Appointing Agents		                                                   25
       3.1.	 Application Process 	                                            25
       3.2.	 Agent Management Models	                                         28
       3.3.	 Contracting Agents	                                              32
    4.	 On-going Agent Management – Relationship Building		                   35
       4.1.	 Ongoing Agent Management	                                        35
       4.2.	 Communication	                                                   37
       4.3.	 Marketing and Promotion	                                         39
       4.4.	 Record Keeping	                                                  40
       4.5.	 Managing Issues	                                                 41
    5.	 Review of Agents		                                                    42
    6.	 Exit Strategies		                                                     42
       6.1.	 Non-Compliance	                                                  44
4    International Education Agent Management | A Best Practice Guide
SECTION THREE: PROVIDER TOOLS AND TEMPLATES		                                                                  46
1. 	 Sample Education Agent Code of Conduct		                                                                   47
2.	 Sample Agent Appointment Monitoring and Termination Policy		                                                48
   1.	   Purpose	                                                                                               48
   2.	   Scope	                                                                                                 48
   3.	   Definitions	                                                                                           48
   4.	   Actions	                                                                                               48
   5.	   Agent Performance Appraisal	                                                                           49
   6.	   Re-appointment of an Agent	                                                                            49
   7.	   Termination of an Agent	                                                                               49
   8.	   References	                                                                                            50
   9.	   Forms/Record Keeping	                                                                                  51
3.	 Sample Application for Consideration to be Appointed as an Education Agent		                                52
   1.	   Sample of an Application Letter	                                                                       56
   2.	   Sample of Provider Information (International Prospectus)	                                             57
   3.	   Example of an Educational Referee Report	                                                              58
   4. 	 Example of a Student Referee Report	                                                                    59
   5.	   Process Checklist: New Agent Application	                                                              60
   6	    Example of Rejection Letter	                                                                           61
   7.	   Example of Education Agent Acceptance Letter	                                                          62
   8.	   Sample Agent Contract 	                                                                                62
   9.	   Example of Education Agent Certificate of Appointment	                                                 74
   10.	 Example of Order Form for Promotional Materials	                                                        75
   11.	 Example of Agents Manual Contents – Version 1	                                                          76
   12.	 Sample Agents Manual Contents (ISANA Report) -Version 2 	                                               77
   13.	 Sample of Agent Database / Register 	                                                                   78
   14.	 Sample of an Agent Annual Communication Plan	                                                           79
   15.	 Sample of Performance Review of Agent Template	                                                         80
   16. 	 Example of an Renewal of Education Agents Contract Letter	                                             81
   17.	 Example of Non-Renewal of Contract Letter	                                                              82
   18.	 Example of Letter of Termination	                                                                       83
4.	 Appendices 		                                                                                               84
   List of Acronyms	                                                                                            84




                                                     International Education Agent Management | A Best Practice Guide   5
SECTION ONE:
    AGENTS AND THE AUSTRALIAN
    INTERNATIONAL
    EDUCATION SECTOR




6   International Education Agent Management | A Best Practice Guide
1.	 Introduction
The global mobility of students has increased at a rapid rate. Over the past three decades the number of
international students quadrupled, from 0.8 million (1975) to 3.3 million (2008).1 Since the late 1990s,
growth has accelerated. In 2008 alone growth was 11 per cent on the previous year.2 Should current
trends in international enrolments continue it is expected that between 4.1 million and 6.7 million
students will be studying abroad by the year 2020.3 Australia’s share of the global international student
market is between 7 and 8 per cent.
Education is Australia’s third largest export industry and Australia’s largest service export, ahead of
tourism.4 The value to the Australian economy of education exports in 2009–10 was $19.1 billion, an
increase of 10.2 per cent on 2008–09. Educational services have grown to become Australia’s largest
services export industry ahead of other personal travel services ($12.1 billion) and professional and
management consulting services ($3.1 billion). In 2010 over 619,000 international students from more
than 100 countries were enrolled to study in Australian institutions. The majority was in higher education
(39 per cent) and vocational education and training (VET) (34 per cent).
Australian institutions actively use an extensive network of commercial agents within target markets
to promote their offerings and to recruit international students. Over 40 per cent of commencing
international students are engaged or introduced through an agent of one kind or another.5 The use
of agents has been a hallmark of Australian international education and has been instrumental in
Australia’s outstanding commercial success. In 2010-11 the Australian international education sector
experienced its first significant downturn and as such providers have needed to reassess the role and
use of agents in their recruitment strategies.
In order to maintain market share and growth in the Australian VET sectors internationally, education
providers need to be increasingly savvy in their approach to business development. International
education agents play a significant role in the international education sector. In fact, International
Benchmarking research conducted by Alan Olsen in 2008 indicates that on average over 50 per cent of
student enrolments were referred by international education agents to the Queensland public VET sector
in that year. Working effectively and efficiently with agents will be crucial to ensuring the Queensland VET
sector can sustain and increase its share of the international education market.

1.1.	 Aim of the Guide
TAFE Queensland International has commissioned this research into agent good practice and prepared
this Guide in order to assist Queensland VET providers in building their capacity and effectively partnering
international education agents.
The specific aims of the research are to:
     •	 better understand good practice in agent management and share the findings with education
        providers and international education agents so Queensland can continue to improve operations
     •	 build a better understanding of the roles and activities that both providers and agents play in the
        international education industry.




1	      OECD (2010). Education at a Glance, p. 32.UNESCO (2009) estimates a total of 2.8 million international students globally
        in 2007. While estimates may vary, being based on different parameters, the overall trend towards significant continuing
        growth is evident.
2	      OECD (2010).Education at a Glance, p. 32.
3	      Calderon, A. (2010).Emerging countries for student recruitment in tertiary education.Paper presented to the IMHE-OECD
        Conference, Higher Education in a World Changed Utterly: Doing More with Less, Paris September 2010, p. 6.
4	      Australian Bureau of Statistics (2010).(ABS Catalogue no. 5368.0.55.004).Note: Includes international students studying
        onshore on student visas only. Export income does not include income generated by the operation of offshore campuses of
        Australian institutions.
5	      Olsen, A. SPRE, (2009)


                                                             International Education Agent Management | A Best Practice Guide      7
Based on the research this Guide has been developed to provide practical tools and techniques for
    providers to work more effectively together with agents to continue to achieve significant growth for the
    Queensland and Australian international education industry.

    1.2.	 The Approach
    The approach and initial research to inform this guide was undertaken in 2009. The outcome of the research
    was the 2009 Agent Management Best Practice Guide, that has been very well received and highly utilised
    across the sector. Since this time there have been a number of changes in market conditions that have
    resulted in the need to review the currency and relevance of the guide content.
    This Guide represents an updated version of the original and provides additional and current references
    and resources to ensure providers maintain efficient practices. To ensure the current edition is timely and
    relevant the following approach was used to inform its development.

    Phase One: Desk Research
    This phase aimed to identify current practice and process in effective international education agent
    management through desk research. A range of articles, presentations, conference papers and
    international education providers’ web sites were reviewed to determine processes. Current legislation
    was also reviewed so that the requirements needed to inform policies and procedures were noted.

    Phase Two: Interviews with Targeted VET Providers and Agents
    Based on the research above, a discussion framework was developed for phone interviews with a targeted
    group of VET providers in Queensland. The targeted providers covered those at various stages of their
    internationalisation. The interviews aimed to identify: current agent management practice for VET providers
    in Queensland and what providers felt was needed to advance or improve their agent management
    activities. Providers were also asked to provide examples of forms, processes and resources that could be
    used to inform the creation of the Provider Templates found in Section Three.

    Phase Three: Report Preparation and Review
    Based on the outcomes from Phase One and Two the final report was prepared for feedback from key
    stakeholders. The final publication is this International Education Agent Management Best Practice
    Guide 2011.

    1.3.	 How to Use this Guide
    This Guide has been developed in three sections:
     •	 Section One provides an overview of the international and domestic market to provide context.
     •	 Section Two outlines the steps of best practice in education agent management.
     •	 Section Three provides a set of tools, templates and resources providers can contextualise to their
        specific business needs.
    Depending on your needs, you can work through the Guide or simply choose relevant sections. Each
    section includes case studies to provide further information and practical examples.


    2.	 What is an International Education Agent?
    An international education agent is often seen as a bridge between the many people involved in
    international education– including students, parents, providers and home-stay families –providing a
    pivotal link between them. Agents can be found across the world with many offering services to the full
    range of providers including language schools (ELICOS), schools, VET providers and higher education
    institutions.
    The specific activities of an agent vary based on provider and student needs, but their core activities are
    generally targeted towards students and providers as follows in Table 1.

8    International Education Agent Management | A Best Practice Guide
Table 1: Core International Education Agents’ Services

 Targeted to Students                                        Targeted to Education Providers

 •	 Providing information on the range of education          •	 Recruiting suitable students for the provider
    options, courses and pathways
                                                             •	 Processing student applications
 •	 Providing information on the preferred countries –
    travel, lifestyle, etc.                                  •	 Offering a translation service
                                                             •	 Providing market intelligence on changes to demand
 •	 Providing education counselling for students to             for courses
    ensure the most appropriate course selection
                                                             •	 Marketing and promoting education providers
 •	 Processing applications to education providers
                                                             •	 Student-related administration
 •	 Processing visa applications
 •	 Supporting students while in Australia

The education agent industry is not regulated in Australia. Agents are not required to be a member of any
particular body, or have any specific training or minimum business requirements. However, there are a
number of quality controls and systems that can assist providers in determining whether they should enter
into a partnership with a particular agent. More detail on this can be found in the Due Diligence section
of this Guide. It should be noted that an education agent that is not a registered migration agent cannot
provide migration advice to a student but can provide advice regarding student visa types.

2.1.	 Types of International Education Agents
There are two key types of education agents. These are:
 •	 inbound student agents
 •	 partnership agents.

Inbound Student Agents
Inbound student agents focus on recruiting students to study in Australia. These agents may be based
either in Australia or offshore or they may have branches in a number of locations. Many agents provide
services to a number of clients in markets across the world. Most often inbound student agents work on a
commission per student recruited.
Providers should be aware that some agents may use the services of a sub-agent – that is, an agent
that feeds students through a lead agent to a provider. As the National Code of Practice for Registration
Authorities and Providers of Education and Training to Overseas Students 2007 (National Code) prescribes
that all providers must have a written agreement with an agent, providers should seek clarification from any
agent if this is practice and how the process is managed. This can be clarified during the agent application
stage.
While not common, some agents may request to be a sole/exclusive agent in a particular market. Providers
should carefully consider the pros and cons of such an agreement and ensure they are not limiting their
options.

Partnership Agents/Business Brokers
These agents focus on developing partnership programs between international providers and/or industry.
Often these agents work on a retainer or commission per project.




                                                         International Education Agent Management | A Best Practice Guide   9
Migration Agents vs. Education Agents
     A migration agent is an individual who has met the minimum requirements to be registered with the
     Migration Agents Registration Authority (MARA). This registration allows them to legally provide immigration
     assistance and advice. For more information and a list of Australian registered migration agents visit
     https://www.mara.gov.au.
     Many migration agents also offer the services of an international education agent and vice versa. Agents
     with both the education and migration skill and knowledge in their organisation may add value to an
     agency partnership. Providers should ensure they understand the primary focus of the agency and their
     strengths as different management styles and approaches may be needed for agents with different skill
     sets. For example, a migration agent may need more support in educational knowledge, such as knowledge
     of Australian Quality Training Framework (AQTF) or the Education Services for Overseas Students (ESOS)
     Act 2000.


     3.	 Why Use an International Education Agent?
     The international education agent industry is highly competitive and working with a good agent can be
     very lucrative for an education provider. While this is the case, the decision to employ an education agent
     should be considered carefully to ensure agents are used most effectively for your organisation. There are
     a number of reasons you may consider using an education agent and a number of reasons you may not.
     These are described below.

     3.1.	 Reasons to Partner with International Education Agents
      •	 Agents can provide innovative marketing and promotional ideas that may be highly relevant to the
         target country.
      •	 Agents with offices or contacts in offshore markets can provide first-hand information on trends and
         opportunities.
      •	 Agents with offshore offices can provide on-ground support and thus reduce the need to travel as
         frequently to markets, reducing the overall business development costs and increasing profitability.
      •	 Agents provide local expertise and have local language and cultural understanding and knowledge.
      •	 Agents can provide access to high-risk markets that may be costly, difficult or dangerous to access.
      •	 Agents can provide a one-stop-shop for students, which may increase students’ overall satisfaction
         with the experience.

     3.2.	 Reasons not to Partner with International Education Agents
      •	 Agents are not regulated in Australia and as such a greater onus is on the provider to select
         quality agents.
      •	 Under the ESOS Act there is a requirement to manage agents and adhere to minimum
         management requirements, using staff resources that could be used for other activities.
      •	 The industry standard commissions paid to agents are significant and providers need to assess
         these costs against direct student recruitment.
      •	 Agents are placed in a position of considerable power, being the business development arm for
         your organisation, and therefore providers need to manage and control their activities.
      •	 There is potential for providers to be targeted by agents that employ illegal and/or unscrupulous
         practices, so considerable due diligence is required.




10    International Education Agent Management | A Best Practice Guide
4.	 Agent Regulation and Control
4.1.	 ESOS Act and the National Code
The National Code of Practice for Registration Authorities and Providers of Education
and Training to Overseas Students 2007
The National Code as it relates to the use of education agents requires that providers:
 •	 use education agents with an appropriate knowledge and understanding of the Australian
    international education industry
 •	 enter into a written agreement with agents you engage to formally represent you
 •	 ensure your education agents have access to up-to-date and accurate marketing information
 •	 do not accept students from, or enter into an agreement with, any agent you suspect to be engaging
    in dishonest practices
 •	 terminate an agreement if you become aware that your agent is acting dishonestly or unethically
 •	 take immediate corrective or preventative action if you become aware of any form of unprofessional
    activity by your agent.


2010 Amendments to the ESOS Act
In 2010, following a review of the ESOS Act, new regulations were introduced in order to improve the
accountability in the use of agents. Under the Education Services for Overseas Students Amendment
(Re-registration of Providers and Other Measures) Act 2010, providers are required to ‘maintain on their
website a list of all persons (whether within or outside Australia) who represent or act on their behalf in
dealing with overseas students or intending overseas students’.
Further proposals were outlined in the ESOS Act review and, if introduced, providers will need to comply.
Providers will need to keep abreast of these possible changes in the future. Suggested amendments
include:
 •	 holding providers more accountable for agents –providers could be fined if their offshore agents act
    unethically
 •	 banning Australian-based agents from charging commissions for luring students from one local
    college to another
 •	 banning providers from paying commissions to agents unless they disclose the identity of the agents
    and their commission arrangements to both students and regulators
 •	 implementing a ‘unique identifier’ to track the colleges attended by each student
 •	 taking some form of direct regulatory action against offshore agents, such as preventing them from
    applying for visas on behalf of their clients, if they fail to meet legislative requirements.
The Government’s final position on the regulatory changes will be informed by proposed consultation and
the feedback received.




                                                    International Education Agent Management | A Best Practice Guide   11
POLICY - Standard 4 – Education Agents

     National Code, Standard 4 (Education Agents):
     Registered providers take all reasonable measures to use education agents that have an appropriate
     knowledge and understanding of the Australian international education industry and do not use education
     agents who are dishonest or lack integrity.
     4.1	 The registered provider must enter into a written agreement with each education agent it engages to
          formally represent it. The agreement must specify the responsibilities of the education agent and the
          registered provider and the need to comply with the requirements in the National Code. The agreement
          must also include:
            a.	 processes for monitoring the activities of the education agent, including where corrective action may
                be required, and
            b.	 termination conditions, including providing for termination in the circumstances outlined in 	
                Standard 4.4.
     4.2	 The registered provider must ensure that its education agents have access to up-to-date and accurate
          marketing information as set out in Standard 1 (Marketing information and practices).
     4.3	 The registered provider must not accept students from an education agent or enter into an agreement
          with an education agent if it knows or reasonably suspects the education agent to be:
            a.	 engaged in, or to have previously been engaged in, dishonest practices, including the deliberate
                attempt to recruit a student where this clearly conflicts with the obligations of registered providers
                under Standard 7 (Transfer between registered providers).
            b.	 facilitating the enrolment of a student who the education agent believes will not comply with the
                conditions of his or her student visa
            c.	 using Provider Registration and International Students Management System (PRISMS) to create
                Confirmations of Enrolment for other than a bona fide student, or
            d.	 providing immigration advice where not authorised under the Migration Act 1958 to do so.
     4.4	 Where the registered provider has entered into an agreement with an education agent and subsequently
          becomes aware of, or reasonably suspects, the engagement by that education agent, or an employee
          or sub-contractor of that agent, of the conduct set out in Standard 4.3, the registered provider must
          terminate the agreement with the education agent. This paragraph does not apply where an individual
          employee or sub-contractor of the education agent was responsible for the conduct set out in Standard
          4.3 and the education agent has terminated the relationship with that individual employee or sub-
          contractor.
     4.5	 The registered provider must take immediate corrective and preventative action upon the registered
          provider becoming aware of an education agent being negligent, careless or incompetent or being
          engaged in false, misleading or unethical advertising and recruitment practices, including practices that
          could harm the integrity of Australian education and training.




12   International Education Agent Management | A Best Practice Guide
4.2.	 Education Agents Peak Professional Body
Prior to 2011 there was no formal monitoring or control of international education agents at a systemic
level; the onus was on the provider to ensure an agent’s standing. In April 2011 the Migration Institute of
Australia (MIA) extended membership in the peak body for the migration advice profession to qualified,
registered education agents. It is not mandatory for an agent to be a member of MIA. Membership, however,
could be used as one of the criteria to determine if an agent is a suitable partner.
The MIA has established a Code of Ethics for Affiliate Education Agents. This Code describes the
requirements that agents must adhere to in order to hold membership. Affiliates must agree to:
 •	 continually strive towards lifting the standard of education Agents within the Australian and
    international communities
 •	 act at all times in a manner that upholds and enhances the integrity and dignity of those working
    within the international education environment
 •	 be open and honest with clients at all times in regards to the scope of services available
 •	 inform their clients that as per the Migration Act, they cannot provide migration advice (unless also
    registered as a Migration Agent)
 •	 commit to ongoing professional development throughout their career and actively assist and
    encourage their fellow members to advance their professional knowledge and experience
 •	 comply with the relevant Acts, Regulations and MIA Code of Conduct when dealing with clients
 •	 make no representation regarding the provision of services that are false or misleading and to fully
    disclose all applicable charges for services, as well as the scope of the services to be provided prior
    to engaging a client
 •	 recognise and respect the rights, dignity and individuality of all persons. A member shall not
    discriminate or knowingly permit discrimination on the basis of race, national origin, sex, sexual
    orientation, religion, age or disability
 •	 avoid conflicts of interest at all times with regard to professional activities, financial considerations
    or other interests. At such time as a member becomes aware that an actual, apparent or potential
    conflict of interest exists, the member must make a full disclosure to the appropriate parties.
For more information visit: http://mia.org.au/educationagent/.
Agents have also established professional peak bodies within their own countries. Each of these
professional bodies has its own code of ethics and can be used as a tool in collecting due diligence
information.




                                                   International Education Agent Management | A Best Practice Guide   13
4.3.	 Additional References and Resources
     As shown in Table 2, a number of publications and resources have been developed to assist providers to
     understand and implement the requirements under the ESOS Act and National Code.

     Table 2: Agent Management Resources

      Publication                                                                           Source

      Education Agents Manual                                                               International Student
                                                                                            Association New Zealand
      http://www.isana.org.au/files/EducationAgentsManual.pdf
                                                                                            and Australia (ISANA)

      Best Practice in Education Agent Management                                           Victorian TAFE International
                                                                                            (VTI)
      http://www.aei.gov.au/Regulatory-Information/Pages/Regulatoryinformation.aspx

      Using Education Agents, A guide for providers of education and training to overseas   Department of Education,
      students                                                                              Employment and Workplace
                                                                                            Relations (DEEWR)
      http://www.pieronline.org/_Upload/Files/Using_Education_Agents_pdf.pdf

      National Code Explanatory Guides                                                      Australian Education
                                                                                            International (AEI)
      http://www.aei.gov.au/Regulatory-Information/Pages/Regulatoryinformation.aspx


     5.	 Managing Agents in Turbulent Times
     In 2010 the Australian international education sector experienced its first significant downturn. Figures
     reported by providers range from a 10 to 30 per cent reduction in student enrolments in 2010 alone. The
     downturn has been attributed to a combination of external factors such as;
      •	 the global financial crisis,
      •	 increased international competition and the appreciation of the Australian dollar,
      •	 and domestic factors such as changes to student visa requirements, student safety concerns,
         changes to the skilled migration program and the commercial failure of a number of colleges.
     Reports indicate that the impact of the downturn was felt across the whole sector and is continuing
     to be felt.
     In turbulent times providers many need to place greater emphasis on:
      •	 being aware of possible risks and unethical practices
      •	 ensuring effective due diligence and monitoring processes are in place
      •	 managing change effectively.




14    International Education Agent Management | A Best Practice Guide
5.1.	 Potential Risks
The relationship between economic downturn and increased illegal activities is well reported. While we
know most agents are honest, reliable and are looking for a mutually rewarding partnership, it is more
likely in difficult times for individuals to take advantage and attempt to gain from illegal behavior. As such
it is advisable for providers to make themselves aware of possible illegal practices that could affect their
business and have strategies in place to pre-empt these. It should also be noted that these activities can
occur from inside your organisation as well as outside. The set of case studies below provides a good
summary of possible fraudulent activities that have been reported across the sector.

  CASE STUDY : Examples Of Rouge Agent Activity

  International Draft Scam – A prospective international student approached a provider to enrol as a student.
  An international draft for tuition fees was forwarded, payable to the provider. The draft was banked. A number
  of days later the international student contacted the provider advising that due to a family tragedy they would
  no longer be able to attend the provider and consequently requested a refund of the fees already paid (the
  figure was close to $10,000). The staff became suspicious and looked into the request. Meanwhile the bank
  contacted the provider to advise that the draft had been dishonoured and appeared to be fraudulent. Clearly
  the intent was to have received the refund prior to the provider being notified of the fraudulent draft.
  Web Scams – In Country Y, where Provider X was operating, an agent set up a website with the URL http://www.
  providerX.countryY.com. The website linked directly to the agent’s own website. Suddenly the other agents in
  Country Y started to complain because it looked like this was the ‘official website of Provider X’, directing the
  enquiries straight to the agent. The other agents assumed the agent was getting preferential treatment but in
  fact he had simply purchased the URL and used it for his own purpose. There is nothing illegal in his action. It
  does, however, compromise Provider X who went to great lengths to ensure the agent change the website and
  stop using the provider name in the URL. The agent complied and they are still partners. Another agent set up a
  website using information and logos of multiple Universities creating the impression that this agent represents
  these institutions. None of the Universities have a formal relationship with this agent. Because the agent is not
  an authentic agent, there is little the Universities can do about the problem. It has proven difficult to protect
  the logos from being downloaded or used in electronic forms.
  Double Dipping Scam – An agent was accused of double dipping on commissions. He sent a second invoice for
  the same student, in the same course. The provider had a system of paying on invoices for multiple students
  with a grand total. They did not have a clear way of recording against the student’s name what was paid and
  when. The second commissions were paid. The agent did it accidentally in the first instance but when it wasn’t
  discovered they tried again successfully and then, of course, it became a lucrative habit. It was exacerbated
  by the fact that sometimes the invoices would arrive months after the student had commenced and the
  provider was not good at tracking its payments over time. A response to this was to set up a new system with a
  unique invoice number for each student. This has resolved the problem. The provider was also concerned that
  perhaps one of the staff who had sole responsibility for paying commissions may have been working by prior
  arrangement with the agent. An audit by an outside consultant identified that a key risk to the Provider was
  having a single person responsible for this commission payment task.
  Conflict of Interest – A Provider’s marketing staff person asked permission to sign up a close relative as an
  agent. At no stage did they alert the Provider that the agent was related to them even though the agent was
  operating in their marketing region and there was a conflict of interest. The scam was discovered but the
  staff person claimed to be innocent of all knowledge of how this could have happened and told a range of
  increasingly unbelievable stories around the matter, consistently denying a conspiracy. Only after extensive
  investigation and confrontation, involving the Provider’s Human Resources section, the Unions and provision
  of irrefutable written evidence did the staff person accept there was something untoward. At this point, even
  though the saga had drawn out over two months, the person’s last resort was to claim that the relative had
  misled them and that they were shocked and appalled. The staff person was married to the agent and lived
  with them at the business address.
  Theft – An agent took a non-refundable up front payment from all students for the services that the universities
  provide free –for example, airport pickup, orientation and accommodation support.
  Modified from Scams and Scammers: Agents and the International Office. A Cautionary Tale, Virginia Pattingale,
  http://www.aiec.idp.com/pdf/Paper_Pattingale.pdf



                                                      International Education Agent Management | A Best Practice Guide   15
5.2.	 Due Diligence and Monitoring
     The process of conducting due diligence and ongoing monitoring and evaluation are a feature of this Guide.
     Section Two of this document provides detailed processes and questions for providers to support their
     agent selection and management. In addition to this resource, providers can also refer to the Partnership
     Due Diligence Best Practice Guide.

     5.3.	 Managing Change Effectively
     The aim of this Guide is to provide strategies and tools to ensure your systems and processes are the most
     efficient and effective they can be. Even if you adopt and apply all the best practice ideas outlined, at times
     your business will be exposed to economic and social conditions that are outside your control. As such,
     providers will need strategies to ensure your business can be sustained through changing conditions.
     In turbulent times providers should focus attention on activities such as:

     Agent Mix
      •	 Review the number of agents you have on your books and your ability to effectively service these. It
         might be that you need to reduce the number of agents you have and provide more focused attention
         to a few.
      •	 Which agents are you working with that provide the best returns and outcomes? Consider the 80/20
         rule and actively work with your top agents to ensure their needs are met and they are satisfied.
      •	 Review the role and services an agent offers.

     Market Strategies
      •	 Review your market diversification. It is important to get the right balance between having sufficient
         source markets to generate enrolments and your ability to service them.

     Service Levels
      •	 Ensure your service levels for administration and course delivery remain very high. Agents will be
         more demanding of providers and be looking for the best product and offering for their clients. By
         maintaining and ensuring a high quality the reputation of your brand is retained, which will support
         future enrolments.

     Coordinating with Agents
      •	 Invite your agents in and discuss the current environment. Consider mutual ways you can work
         collaboratively to maintain business.
      •	 Ensure you maintain regular and engaging communication with your agents. Communication is key
         to any relationship and a solid relationship will lead to enrolments. If face-to-face communication
         is prohibitive due to cost, consider lower cost communication channels such as social networking
         platforms, Skype and email.

     Consider Pricing Strategies
      •	 Carefully consider your pricing strategies. In poor economic times discounting is often used to attract
         business. While this may help business initially it potentially can reduce the perceived value of your
         courses and services.
      •	 Monitor your commission rates and negotiate these wisely. As part of your negotiation with agents
         you may consider increasing your commission provided to agents to be competitive. It is very difficult
         to reduce commissions once you have increased it. It may be more appropriate to consider other
         incentives. Providing part scholarship per x enrolments may be a low cost option if your fixed costs
         are met for a particular course.




16    International Education Agent Management | A Best Practice Guide
Creative Promotion Strategies
 •	 Consider joint promotions with other providers in a promotion consortium to reduce marketing costs.
    This could include shared offshore agents visits.

Monitor and Review
 •	 It is important to use monitoring activities to know your position and adjust your strategies as
    required.
Section Two of this Guide provides detail on these activities and a step-by-step guide to managing
your agents.




                                                 International Education Agent Management | A Best Practice Guide   17
6.	 Strategically Managing Your Business
     Strategic management is a key element in the success of any business or project. The purpose of this
     Guide is to provide practical advice and tools to optimise the provider–agent relationship. It is important to
     understand your organisational objectives, operating environment, and identifying strategic activities. This
     understanding leads to establishing a transparent document that can be adopted by the whole institution
     to drive successful provider–agent projects. Identifying, appointing and managing agents should be
     identified as a key strategic activity for your organisation.

     Figure 1: Agent Management within a Strategic Framework


       IDENTIFY AGENTS based on
         › Organisational Objectives
         › Market Objectives



         ORGANISATION                    INTERNATIONAL
         STRATEGIC PLAN                ORGANISATION PLAN


                                            Financial Management Plan


                                                Organisational Plan
                                                                              SELECT AGENTS

                                                  Marketing Plan
                                                                                 Conduct Due Diligence


                                                                                  Contract/Agreement


                                                                                  Agent Management


                                                                                        Review


                                                                                         Exit




      •	 the types of agents are identified on the basis of your organisational and international objectives.
         This should be considered and finalised during the strategic planning process. What kind of agent do
         you need to appoint in a particular market to assist in meeting market objectives?
      •	 Agents are selected on the basis of ‘best fit’ in meeting your goals in a particular market. Does the
         agent being considered offer skills and services that are needed to meet market objectives?
      •	 Agent management is built into your international plan and internal management model with:
         --   internal positions/staff designated for the ongoing identification, recruitment, management and
              review of your agent network
         --   information management systems identified for the ongoing monitoring and record keeping
              involved in managing agents
         --   the costs of managing agents included in your financial management plan.




18    International Education Agent Management | A Best Practice Guide
SECTION TWO
THE AGENT MANAGEMENT PROCESS
1.	 Best Practice in Agent Management
1.1.	 Steps in Agent Management
Five key steps have been identified as best practice to ensure effective agent management.  The process
is cyclical with ongoing identification, management and review occurring at different times depending on
the business needs, market conditions and agent activities. These five steps are:


     Identify                  Appoint            Manage                      Review                    Exit


Figure 2: The Agent Management Process




                                                                3. ONGOING AGENT
                 1. IDENTIFY AGENTS
                                                                   MANAGEMENT


                      assess internal needs                          conduct initial training


                          identify agent                            conduct refresher training


                                                                     develop communication
                                                                           approach
                2. APPOINTING AGENTS



                    agent completes application
                                                               4. REVIEW OF AGENTS

                       conduct due diligence

                                                                       review performance
                       decide on approach to
                         service provision
                                                                    re-negotiate performance
                                                                          requirements
                     agree on terms of business

                                                                         re-sign contract
                       agree on performance
                             indicators


                         develop contract
                                                                5. EXIT STRATEGIES

                       provide certificate of
                          appointment
                                                                  terminate contract if required


                         forward student                                     appeal
                        information packs




                                                  International Education Agent Management | A Best Practice Guide   19
Identify                 Appoint                    Manage             Review                   Exit




     2.	 Identifying Agents
     There are numerous types of agents and hundreds of different businesses operating as agents internationally
     and locally. If you are a large, well-established provider to international students, in many instances agents
     will seek you out. Smaller providers however, or those new to the international education industry, may
     have to actively search for agents to appoint. No matter which category your organisation falls into you
     need to have a clear understanding of agents and their role in each market. You should consider:
      •	 market alignment – the market objectives and client needs that the agent will service
      •	 agent alignment – your business needs or objectives that the agent will service.
     Investigating these questions at a macro level will assist in identifying agents that align with your business
     needs and objectives in a market as well as market-specific issues that may need to be addressed.

     2.1.	 Market Alignment
     Every market is different and should be approached in a unique way. Agents may have different roles, offer
     different services and operate at different levels of accessibility in different countries. You need to research
     the market in the context of the needs of the students and the services offered by agents, as well as other
     market issues such as visa processing, the relationship between agents and governments, and regulation
     of agents.
     In investigating the market you should consider the following:
      •	 Is the use of an agent an effective market strategy to meet your organisational objectives?
      •	 What are the particular market trends? Are they whole-of-country based or regionally based? Large
         countries such as India, China, and Russia have niche regional markets and may require different
         strategies and agents to be employed in each one. In other markets, such as Scandinavia, it is the
         ‘done thing’ to employ and work closely with only one agent. The Scandinavian market, although
         covering several countries, tends to be more similar than many regional markets within the same
         country.
      •	 Where is Australia placed competitively in the market? Is Australia’s market share large or small?
         Does this affect the agent–provider relationship? For example, in Malaysia and China there may
         be agents that focus solely on Australia because of the size of Australia’s market share. In other
         countries, such as Russia, Australian agents will service a number of different markets so providers
         may have to maintain these agents more to gain some competitive advantage.
      •	 Are there any particular market issues affecting agents? For example, in countries where there is a
         high corruption index this may affect a particular agent’s ability to process student visa applications
         or affect your management of an agent.
      •	 Are there any in-market government regulatory requirements concerning agents?
      •	 More agents are employing an ongoing-care strategy with students, which does not necessarily end
         when their commission is paid. Agents sometimes provide support, advice and services prior to,
         during and following students’ first qualifications.
     Investigating these areas and others will help you build a profile of agents’ roles in each specific market
     and assist you in targeting your search if you do identify agents as a key strategic activity.




20    International Education Agent Management | A Best Practice Guide
Approaches to Agents by Market
Working with agents requires a unique approach for each market to ensure the local needs, regulations
and customs are adhered to. It is recommended that the legal, financial, institutional and cultural
considerations be addressed for each market in which you intend to work. Understanding and flexibility
are required. It is also important to consider the timing adopted for each market. As outlined in Table 3,
education and training dates vary for different markets.

Table 3: Indicative timing of key term dates for selected markets

 Market                    Term 1            Term 2             Term 3             Term 4             School Year
                                                                                                      Finishes
 Australia                 February          April              July               October            December
 North & Central America   September         December           February           April              July
 Continental Europe        August            October            January            April              June
 Japan                     April             September          January            -                  March
 South America             February          April              July               October            December

Implications for agents:
 •	 Have material ready.
 •	 Negotiate the strategic use of conditional offers to fit into timing – i.e. give a conditional offer on the
    basis of incomplete results.
 •	 At peak times make sure providers are well resourced. Resource planning is necessary.
 •	 Have appropriately trained staff – for example, culturally aware staff.

   CASE STUDY : Education Agent Requirements by Market

   The Chinese Government introduced laws to regulate the activities of agencies providing advice
   to Chinese students about going overseas to study. These laws regulate the activities of student
   recruitment agencies in China, not students or overseas institutions. The laws require agencies to
   be registered with the National Government, via a process of nominations from provincial/municipal
   authorities. No foreign organisations are permitted and unapproved agents are prevented from
   advertising. The laws prevent agents from actively recruiting students at secondary schools (children
   under 15 years of age). There are nearly 400 agents approved by the Chinese Ministry of Education. A
   full list of approved agents is available to purchase from Austrade Beijing. Providers seeking to deal
   with agencies that claim to have national approval should refer to this list. More information can be
   gained through Austrade in China.

2.2.	 Agent Alignment
Assessing the market will provide you with a clear understanding of whether your business objectives will
be met by appointing an agent in-market or whether other strategies would be a better use of resources. It
will also provide you with information to select agents that align with your objectives in-market, specifically:
 •	 the type of agent required in-market
 •	 the client maintenance expectations of the market, which will determine whether you should appoint
    an agent onshore or offshore
 •	 how agents monitor the market trends and demand for your product and how competitive the
    market is
 •	 the number of agents needed to service the country, given regional niche markets. Does each region
    require a different agent or can one agent, through their networks, service the whole country?

                                                       International Education Agent Management | A Best Practice Guide   21
Onshore vs. Offshore
     Many agents have offices based in Australia to provide ongoing service for their students and to establish
     a stronger relationship with providers. Most Australian-based agents have affiliated companies based in
     their target market. They usually travel offshore to recruit students on your behalf. The advantage of an
     onshore agent is that they have a high level of accessibility to you and your organisation. An offshore-
     based agent, however, may have more accessibility to in-market information and potential partners. An
     agent who has a large network both in Australia and offshore would have both benefits.
     You may need to monitor the legislative changes to the ESOS Act. One recommendation that has been
     made is to require more accountability for onshore agents, such as banning the payment of commissions
     should an onshore agent be caught poaching students from one provider to the other.
     As shown in Table 4, a simple matrix of the markets you wish to target and the number of agents you have
     servicing that market can help you manage and plan the search for agents. Note that markets can be as
     dynamic as they are diverse, so an agent environmental analysis should be conducted regularly to ensure
     your agent management strategy is following market trends.

     Table 4: Market–Agent Matrix

      Market                         No. of Students Target          No. of Agents Contracted   No. of Agents Needed
      China                          30                              0                          2
      Japan                          20                              2                          1
      India                          50                              3                          4
      Total                          100                             5                          7

     Quality vs. Quantity
     It is important to know your agent market and plan as much as possible. However, the decision to appoint
     a certain number of agents in a market is not always a strategic one. There are generally two approaches
     within industry to selecting and appointing agents:
      •	 appointing a minimum number of agents with whom you build quality relationships. These agents
         usually refer large numbers of students to your institution.
      •	 appointing a large number of agents in a market. This strategy involves appointing several agents
         who each refer small numbers of students to your institution. Collectively they make up your country
         enrolment target. It is much more difficult to manage large numbers of agents effectively or to build
         strong sustainable relationships in using this strategy.
     There are benefits to each approach. It is probably a natural progression that a smaller VET provider, starting
     out internationally, would initially appoint a larger quantity of agents. As they grow and establish strong
     relationships with key agents, they reduce the number of agents working with them. This progression is not
     always strategically driven: as an organisation grows internationally and establishes a brand in-market this
     places them in a better position to negotiate and establish a quality relationship with the more successful
     agents in-market.




22    International Education Agent Management | A Best Practice Guide
CASE STUDY : The Changing Nature of Agents

  IDP Expands to Recruit for Alternate Markets
  IDP Education has become the world’s largest student placement firm, operating more than 70 counselling
  centres in more than 20 countries and placing more than 300,000 students. It was jointly owned by 38
  Australian universities and a leading online recruitment firm. IDP has been placing students into Australia for
  more than 20 years. In 2009 the organisation expanded into the United States and since that time has built the
  largest portfolio of university partners of any agency worldwide. IDP has now further expanded into the United
  Kingdom, Canada and Turkey and is continuing its growth into a multi-source, multi-destination placement
  organisation.

2.3.	 Sources of Agent Contacts
International education agents can be found in countries throughout the world and there are many ways
providers can identify suitable agents. It is now a requirement under the ESOS Act for all Australian
providers to list their agents publically on their website. While this can be a good source of potential
agents, providers should always conduct their own due diligence on these agents to ensure they are
strategically aligned to your business. Table 5 provides a summary of some possible sources of agents you
may consider.

Table 5: Sources of Agent Contacts

 Source                          Description

 Austrade                        http://www.austrade.gov.au/

 International Education         ICEF: http://www.icef.com/
 Agents Fairs (ICEF)

 Local onshore Agents            Trade Queensland
                                 Australian-based, country-specific associations: for example, the Singapore
                                 Malaysian Association of Australia
                                 telephone books
                                 Chamber of Commerce and Industry
                                 other providers

 Internet                        web searches

 Networking with other           other registered training organisations
 Providers
                                 other sectors

 Web search Provider Agent       published provider lists of educational representatives either on their websites
 Lists                           or through their international prospectuses

 International Education         Austrade Fairs
 Student Fairs

 Queensland Government           http://www.export.qld.gov.au/contact-us.html#international
 Offices Offshore




                                                     International Education Agent Management | A Best Practice Guide   23
Professional International        www.pieronline.org.
     Education Resources (PIER
     Online)                           for a full list of Qualified Education Agent Counsellors: http://www.pieronline.
                                       org/qeac/mobile.aspx

     Direct to you                     Internet site

     Offshore providers and agents     introduction via networks in different markets

     Advertising                       expressions of interest/tender

     Agent Associations                Migration Institute of Australia (MIA) http://mia.org.au/educationagent
                                       The Federation of Education and Language Consultants has a world wide
                                       network of Agents Associations (FELA): http://www.felca.org/
                                       Association of Australian Education Representatives in India (AAERI): http://
                                       www.aaeri.org/




24   International Education Agent Management | A Best Practice Guide
Identify                 Appoint            Manage                     Review                     Exit




3.	 Appointing Agents
At this point you have assessed the market, identified the use of agents as a key recruitment strategy,
and determined the type of agents you require. You now need to select specific agents to implement
your strategy.
Appointing and using agents as a recruitment strategy can be very effective; however, it is not without its
risks. It is essential that appointed agents act ethically and professionally. From a marketing point of view
agents are generally the first point of contact clients have with your organisation. A bad first impression
can damage your in-market reputation. Also, there is a legal obligation through the National Code for
providers to ensure that agents are honest.
A number of providers have developed an Agent Code of Conduct as a public means to articulate their
requirements for agents. Proposed amendments to the ESOS Act as described in the Baird Review will place
greater onus on the provider to manage agents. As such it is important that you state your expectations up
front. It is advised that your Agent Code of Conduct is placed on your website for easy access.

 POLICY : The National Code (2007): Standard 4 – Education agents, Outcome of standard 4
     Registered providers take all reasonable measures to use education agents that have an appropriate knowledge
     and understanding of the Australian international education industry and do not use agents who are dishonest
     or lack integrity.67


3.1.	 Application Process
The appointment of an agent involves three steps:
     1.	       Undergoing due diligence through an application process
     2.	       Establishing the kinds of agent management models you are going to use
     3.	       Formalising your partnership through a contract.
To reduce the risk associated with partnering with a non-desirable agent, many providers have implemented
an application process during which due diligence of the agent is conducted. The application process is
also an opportunity to identify agents best suited to your organisation’s needs in the market: you can
find out how far their networks reach and potential market strategies they are going to implement. It is
recommended that your agent application form be divided into four sections:
     •	 Due diligence – where the corporate profile, organisational structure and referees are established
     •	 Training and educational qualifications – where potential agents’ knowledge of the Australian
        education industry and training qualifications is established
     •	 Market information – where knowledge of the target market, services being offered and in-market
        strategies are established
     •	 Services they will offer.




6	         http://aei.gov.au/AEI/CmsTemplates/GeneralTemplates/LandingPage.aspx?NRMODE=Published&NRNODE
           GUID=%7b2F9C1196-4B2B-49A8-A64A-67B003520F81%7d&NRORIGINALURL=%2fAEI%2fESOS%2fDefault.
           htm&NRCACHEHINT=ModifyGuest
7	         http://www.aei.gov.au/AEI/ESOS/NationalCodeExplanatoryGuide/PartD/Standard_4.htm


                                                       International Education Agent Management | A Best Practice Guide   25
3.1.1.	 Due Diligence
     The main purpose of due diligence is to ensure the agent you are appointing is honest and professional.
     There are two reasons to conduct due diligence on any potential agents:
      •	 Under Standard 4 of the National Code, providers must not make an agreement with an agent who
         has been engaged in dishonest and unethical practices or who has provided unauthorised migration
         advice.
      •	 Agents are usually the first point of contact between you and your potential students. The agent’s
         professional conduct is essential to maintain the integrity of your reputation as well as, more
         generally, Australia’s reputation as a quality provider of international education.
     You should thoroughly investigate the potential agent before appointing them. Most due diligence can be
     conducted through use of an application form, filled out by the agent, and contacting referees. Information
     sourced directly from the agent should collaborate with other sources such as government agencies,
     referees, agent associations and networks as well as your own industry networks.
     Areas for consideration in due diligence are:
      •	 the company profile
      •	 the owners and executives involved in the company. Pay particular detail to establishing whether
         anyone connected with the company has been involved in any bankruptcies, legal proceedings or
         liquidations
      •	 any sub-branches or affiliated companies, if the company is registered
      •	 the company’s financial probity
      •	 how long the company has been established
      •	 at least two educational referees, preferably Australian-based
      •	 possibly two student referees to ascertain the level of service the agent provided them, although this
         is not common practice within the Australian international education industry.

     3.1.2.	 Training and Educational Qualifications
     This section of the application form should establish the agent’s knowledge of the Australian education
     industry. It should assess:
      •	 their familiarity with the Australian Department of Immigration and Citizenship (DIAC)—the visa
         application process and where to find changes to student visa requirements
      •	 their familiarity with the ESOS Act and associated National Code through the Department of
         Education, Employment and Work Relations (DEEWR) website
      •	 whether they are Qualified Education Agent Counsellors (QEAC). The Education Agent Training
         Course (EATC), delivered online by PIER is the result of collaboration between Australian Education
         International (AEI), DIAC and Australian international education peak bodies. The EATC covers four
         areas: Australia, the Australian Qualifications Framework (AQF) and career trends; Legislation and
         regulations; Working effectively in international education; and Professional standards and ethics.
         Qualified agents are listed on the Qualified Education Agent Database (QEAC) at http://www.
         pieronline.org/qeac/default.aspx.
      •	 whether they are qualified Migration Agents under the Migrant Act. If not, do they understand what
         they can and cannot promise regarding Australian residency?




26    International Education Agent Management | A Best Practice Guide
•	 whether they hold any other relevant memberships or licenses. For example, you would ask agents
    from China to provide a copy of the Chinese Ministry of Education Registration Certificate with the
    agent registration number; alternatively, if the agent is based in Australia, ask for evidence that they
    are partnering with a registered Chinese education agent based in China.
 •	 whether they are an affiliate member of the Migration Institute of Australia (MIA).

3.1.3.	 Market Information
The application should also allow agents to show their knowledge of their geographical territory or market.
Ask for details of:
 •	 the potential market
 •	 the geographical area the agent will service and how they will service it
 •	 the agent’s strengths in these areas
 •	 the number of students they handle each year
 •	 their proposal for promotion and marketing in the territories, including the events they will organise
    and attend on behalf of your organisation.

3.1.4.	 Services
Finally, you should ask for details of the services the agent is prepared to offer as part of the agency
agreement. The range of services will depend on the type of agent, their qualifications, market demand
and the facilities they have in country. All agents should offer the following services as a minimum:
 •	 undertaking basic promotion and marketing
 •	 providing information to prospective students on your courses, campus, facilities and other
    information required under Standards 4 and 5 of the National Code
 •	 assisting in the recruitment of prospective students by providing advice on completing application
    forms and submitting them to your organisation
 •	 arranging for English language testing of prospective students
 •	 assisting prospective students with completing and submitting Australian immigration visa
    applications with the Australian Embassy.
Additional services may be negotiated depending on the market and the agent’s qualifications and
licenses. For example, if the agent is located in Australia and is registered as an official migration agent
they may be able to provide a migration advisory service to the student. If they are a travel agency they
can organise airfares and accommodation in Australia. If one of your goals is to form partnerships in the
target market some agents may act as a partnership broker between you and other overseas institutions.
Services can be defined in more detail within the agreement. However, the application form will provide
some information on the potential services the agent could offer.
Note: The most successful agent–provider relationships are based on mutually beneficial and equal
partnerships. Therefore it is important to provide information on your organisation to the agent when
asking them to complete the application form. You should also encourage them to complete their own
due diligence process on you. The partnership will only work if there is a genuine alignment of business
objectives and ethos.
The best way to establish the scope of an agent’s services and market knowledge is to ask for a promotion and
marketing plan for their specified territory. The plan could be seen as a Capacity Statement demonstrating
what the agent knows, will do and can do to meet your business objectives. It should cover the following:
 •	 This is what we know about you.
 •	 This is our understanding of your needs.
 •	 These are the services we will provide you to assist in meeting those needs.

                                                  International Education Agent Management | A Best Practice Guide   27
3.2.	 Agent Management Models
     After identifying an agent you want to appoint, and before contracting them, you need to decide on the
     scope of their appointment, specifically:
      •	 the service provision—what roles and responsibilities will they have?
      •	 commission structures—how will they be remunerated?
      •	 incentive Management Models—are there rewards for exceeding goals and obligations?

     3.2.1.	 The Service Provision
     What services will the agent offer? What role will they play in promoting, marketing and recruiting for your
     organisation? The roles and responsibilities should be based on your business’s strategic objectives and
     priorities. You should keep in mind why you are appointing the agent in that particular market and the
     services the agent offers, and align the service provisions accordingly.
     If the agent is newly appointed, you may wish to enlist them to provide only minimum services to the
     market. As the relationship grows you could increase the service provision. You should note that the more
     high-level services you require, the more your responsibilities towards the agent will increase, such as
     training, monetary support and time. Table 6 below shows suggested service provisions and examples of
     the level of service that an agent may offer.

     Table 6: Service Provision and Level of Agent Support
      Services             Basic                              Intermediate                     High

      Promotion            Easily available and               Joint promotions such as         Regional advertising
                           accessible in shop front.          interviews when provider is      campaigns; agent
                                                              in market.                       representing provider at
                                                                                               events.

      Marketing            None.                              Translating marketing            Exclusive marketing plan
                                                              material.                        organised by the agent
                                                                                               including marketing events
                                                              Provider involvement in the
                                                                                               and advertising.
                                                              agent’s marketing plan.

      Market Research      Basic information on market        New market trends and            Follow-up in market for
                           features.                          demands as they come to          students who have not
                                                              light.                           converted into enrolments.

      Customer             Student Counselling.               Advice on migration and visa     Issuing offer letters and
      Service                                                 application (if the agent is a   Confirmations of Enrolment
                           Advice on educational
                                                              registered Migration Agent).     (COEs) on behalf of
                           application.
                                                                                               provider.
                                                              English language testing.
                           Assistance with visa
                           application.
                           Pre-departure orientation.

      Alumni               None                               Alumni events and follow up.     Maintaining in country
                                                                                               alumni database.

      Business             None                               Introduction and advisory        Partnership brokering and
      Development                                             service for partnerships in      negotiation on behalf of
                                                              education and industry.          provider.

      Servicing for        None                               Through regional events and      Through regional offices
      regional areas                                          promotion.                       and sub agents.


28     International Education Agent Management | A Best Practice Guide
Remember that, as in any relationship, you need to build trust with the agent and the agent with you. Only
appoint agents for services you are comfortable with them performing. As the relationship develops the
service provisions can be changed and expanded.

3.2.2.	 Remuneration
The most common way for the remuneration of agents is through payment of a commission. The agent is
paid a percentage of the tuition fee once the student has paid their fees and commenced their studies.
The industry standard varies but feedback from VET providers indicates that commission rates on average
are 15 per cent for a formal qualification and 20 per cent for ELICOS.8 Some organisations, in an effort to
gain the competitive advantage over other providers, have offered up to 40 per cent commission. Careful
consideration needs to be given to the long-term economic viability of this approach, as opposed to using
that money in marketing support for the agent. The biggest advantage of payment by commission is that
the agent does not get paid if they do not recruit any students. However, a disadvantage is that, usually
because agents work for a number of different providers, if they are recruiting large numbers for your
competitor there is no incentive for them to re-route those students to your organisation. They get paid
either way.
Other payment models include:
     •	 set fee per student.
     •	 retainer. The agent is contracted to represent your organisation over a specified period of time to
        recruit students. It is recommended that this type of financial model be used more as a consultancy
        contract for a specific objective rather than a long-term market strategy.
     •	 agent administrative fees. The agent charges the students a fee. This is usually packaged and
        may include tuition fees, air flights, accommodation, etc. This method of payment is rarely used.
        However, some agents do charge the institution a commission fee and the student an administrative
        fee. You need to clarify whether an agent is charging students fees in addition to your commission
        payments. If they are, what added value are they providing the students? Associating yourself with
        an agent who is fleecing extra money from students can damage your reputation as well as expose
        you to non-compliance of the ESOS Act. It is essential you are clear on your agent’s services and
        payment methods.
When considering which model to use, look at the environment and assess which model would provide
you a competitive edge while taking into consideration the long-term effects of any strategy you employ.
One strategy employed by a number of organisations is to couple the payment of a basic commission with
an Incentive Management Model.

3.2.3.	 Incentive Schemes
As the international education industry becomes increasingly competitive, agents are a major source of
student recruitment for providers. To manage agents more strategically, reward agents who are working
well and gain a competitive advantage over competitors. Many organisations are using incentive schemes.
Incentive schemes can take many forms and may include financial or non-financial incentives. Types of
incentive schemes include:
     •	 discounting. Agents are offered reduced tuition fees for the students they recruit. Discounting is
        used by some providers to encourage the agent to route the students to their organisation rather
        than a competitor. Careful thought needs to be made before offering this incentive. Discounting can
        seriously undermine your position and attract students who are not necessarily part of your target
        market. Discounting can lead to a reduction in the quality of student being referred and devalue
        your courses.




8	      Feedback collected during consultation with Queensland VET Providers.


                                                             International Education Agent Management | A Best Practice Guide   29
•	 variable commission rates. Additional percentages of commission rates are included as an incentive
         for your agent to perform better for you. For example, if they have completed the EATC they get
         an additional 1 to 5 per cent commission above their basic rate. This can be an effective tool to
         encourage your agent to perform better services for you. However, effectiveness will depend on the
         agent, the size of your organisation, and the number of students the agent is sending to you. This
         strategy may be less effective for smaller organisations where the number of students being sourced
         through one particular agent can vary significantly.
      •	 scholarships. Scholarships are offered to high-performing agent counsellors in the form of
         Certificates, Diplomas, short courses or even the EATC. These can be particularly effective for
         building relationships between you and the agent. Offering a scholarship or other professional
         development opportunity will also increase the skills and knowledge of your agent.
      •	 familiarisation visits. You offer to pay for your agent to visit your institution and meet relevant
         staff face-to-face. This increases your agent’s knowledge of your institution and personalises the
         professional connection by allowing your admission officers to meet the agents.
      •	 additional marketing support. This could be financial or physical support, whether by organising
         more joint promotions in-country or providing more financial support for marketing activities.
     You may want to use one or a combination of these incentives to motivate your agent – a combination of
     financial and non-financial incentives seems to be most effective.
     The decision of whether to use an incentive scheme or whether you can engage and motivate your agents
     one-on-one will depend on your resources, size and long-term growth plans. For example, if you have
     appointed a small number of agents they might be easily managed personally; however, unless you have
     a dedicated agent manager as you grow and appoint more agents, you might want to consider managing
     your agents within a management model.
     Many larger VET providers and universities are now using Incentive Management Models to strategically
     rank and provide incentives for their top performing agents. Agents are categorised and ranked against
     selection criteria based on performance and the provider–agent relationship. The selection criteria again
     should be based on your institutional objectives and should be at a macro level to account for market
     level diversity.
     For example, Table 7 illustrates how agents may be ranked into four levels depending on their performance
     in recruiting and their length of association with the organisation. Agents are recruited as bronze agents and
     then, through consistently achieving and exceeding their key performance indicators, can be recognised
     and rewarded for their loyalty and hard work.

     Table 7: Agent Rankings

      Rank        Description                                              No. of Students     Revenue target

      Bronze      New agents                                               < 20

      Silver      Existing agents demonstrating growth in students         > 20
                  numbers and meeting minimum targets

      Gold        Key agent in targeted markets                            > 40
                  Use of sub-agents to recruit large numbers of students

      Platinum    As above plus                                            >50                  $ 500,000
                  Business development activities for industry and
                  institutional partnerships

     Each level offers incentives and rewards to encourage progression to the next level, as shown in Table 8.


30    International Education Agent Management | A Best Practice Guide
Table 8: Agent Incentives and Rewards

 Relationship Structure                                         Bronze       Silver       Gold          Platinum

 Length of Agreement                                            1 year       2 years      3 years       3 years

 Performance Review                                             6            1 year       1 year        1 year
                                                                months

 Monthly report                                                                                        

 Incentive / Benefits

 Commission rate - ELICOS                                       20%          20%          20%+3%        20%+ 4%
                                                                                          over          over target
                                                                                          target        revenue
                                                                                          revenue

 Commission rate - Diploma                                      15%          15%          15%           15%

 Commission rate – Other (Study tours, etc)                     -            -            10%           10%

 Commission rate based on revenue                               -            -            -             1.5%
                                                                                                        revenue
                                                                                                        generated

 Familiarisation visit – assistance arranging visits                                                 

 Partner Certificate                                                                                 

 Regular newsletter                                                                                  

 Listing on web site                                                                                 

 Training support – web based                                                                        

 Scholarships scheme                                                                                  

 Familiarisation visit - paid visit to Queensland                                                      

 Promotional Budget - $2000                                                                            

 Agreement administrative / marketing expenses paid                                                    

 Training support (in person)                                                                          

 Signage on site                                                                                        




                                                       International Education Agent Management | A Best Practice Guide   31
3.3.	 Contracting Agents
     POLICY: The National Code (2007) Standard 4.1 states:
     The registered provider must enter into a written agreement with each education agent it engages
     to formally represent it. The agreement must specify responsibilities of the education agent and the
     registered provider and the need to comply with the requirements of the National Code. The agreement
     must include:
     •	 processes for monitoring the activities of the education agent, including where corrective action may be
        required, and
     •	 termination conditions, including provision for termination in the circumstances outlines in Standard 4.4.

     In addition to compliance with the National Code, the contract provides a document of reference to manage
     your relationship with the agent and the agent with you. As a minimum the agent contract should include:

     Service Provisions
      •	 roles and responsibilities of each party
      •	 a clear indication of the territory or geographical area the agent is responsible for

     Key Performance Indicators
      •	 Key Performance Indicators including student targets, processing times and partner introductions

     Incentives
      •	 incentive schemes
      •	 commission structures

     Basic Contractual Concerns
      •	 the duration of contract and termination clauses
      •	 provision for the document to fall within Australian legal jurisdiction whenever possible.
     As with any legal document it is essential this be reviewed by your organisation’s legal representatives.

     3.3.1.	 The Service Provision
     The roles and responsibilities should be based on your business strategic objectives and priorities. You
     should keep in mind the reasons you are appointing the agent in that particular market and the services
     the agent offers and align the service provisions accordingly.
     If the agent is a new agent you may wish to appoint them to basically serve the market. As the relationship
     grows you could increase the service provision. You should note that, the higher the level of services you
     require, the higher your responsibilities towards the agent, such as increases in training, monetary support
     and time.

     Clearly Defined Territories
     It should also be made clear which geographical areas the agent is servicing. This will make it easy for you
     to manage your agents as well as stay focused on your organisational needs and objectives. There are a
     number of reasons for this:
      •	 Different markets may need different approaches. The agent you have appointed for a particular
         market may not be suitable to meet your objectives in a different market.
      •	 An agent expanding or encroaching into another territory may have implications on your relationship
         with existing successful agents or partners in that territory.
      •	 You may not have the resources to service another market.


32    International Education Agent Management | A Best Practice Guide
To clarify this, it should be noted that agents’ territories might be defined but not the nationalities they
can recruit. For example, an agent servicing Slovakia would be able to recruit a Korean student if they were
recruited within that territory. A Taiwanese agent based in Brisbane might have a defined territory of South
East Queensland and Taiwan. The size of the territory would be up to you and the nationalities of those
recruited within the territory would not be restricted.

3.3.2.	 Key Performance Indicators
Once the services have been decided and documented, key performance indicators (KPIs) should also be
established. KPIs should be established together so the agent has some ownership over them and they are
also realistic. There is no point setting a KPI of 50 students when you are a small provider with a population
of 100 international students. If the KPIs are unrealistic then the agent will not work productively for you
and the partnership will not reach its potential. Examples of KPIs include:
 •	 number of student applications sent by agent
 •	 conversion percentage of applications to enrolments
 •	 length of application processing times
 •	 number of partnership introductions made.
As mentioned, KPIs will depend on the agent and the market. An agent who primarily provides business
development services and recruits students through these opportunities would have different KPIs to an
agent who primarily recruits students through a number of promotional and marketing activities such
as student recruitment fairs. Ranking and incentives schemes can encourage agents to work above and
beyond their KPIs.

3.3.3.	 Remuneration and Incentives
Payment procedures and incentives should be clearly stipulated in the contract and strictly adhered to.
If using incentives or an Incentive Management Model, these should be clearly documented either in the
body of the contract or in the form of an attached Schedule.

3.3.4.	 Basic Contractual Concerns
As per all legal documents, the following should be included in any agent contract:

Length of the agreement
Most providers have a basic 12-month validation period from the time the agreement is signed. The length
of the contract will depend on a number of factors including: your relationship with the agent; the resources
you have to conduct a review and renewal of agreement; and your positioning in the marketplace.
If you are using a management model and you have a long and established relationship with your agent,
the term may be three years. If it is a new partnership, you might want to have a probationary period of six
to twelve months.
If you are a small provider you need to consider the resources you have to conduct reviews and renewals
of agents. If you have over 50 agents and all agreements expire at the same time it might be a large job
to review and renew all of them. If this is the case you may want to consider a management model and
ranking your agents.




                                                   International Education Agent Management | A Best Practice Guide   33
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Agent management-best-practice-guide

  • 1. DEPArTMEnT of EDucATion, TrAininG AnD EmploymEnT Queensland VET Sector International Education Agent Management A Best Practice Guide for Agent Management Department of Education, Training and Employment Queensland Government Australia
  • 2. TAFE Queensland international Department of Education, Training and Employment Education House 30 Mary Street Brisbane Qld 4000 PO Box 15033 City East Qld 4002 EmAil: TAFEQueenslandinternational@deta.qld.gov.au WEB: http://training.qld.gov.au/international December 2011
  • 3. Queensland VET Sector International Education Agent Management International Education: Best Practice Guide Series Department of Education, Training and Employment Queensland Government, Australia
  • 4. Acknowledgments The International Education Agent Management Best Practice Guide (the ‘Guide’) has been developed by the International Education Resources Group for the Queensland Department of Education, Training and Employment. Copies of the Guide and associated resources are available on the Queensland Department of Education, Training and Employment website at http://training.qld.gov.au/information/tafe-qld- international/best-practice-guides.html. Requests for Information This Guide contains ideas and examples of recognised industry good practice in international education agent management. It has been developed in good faith to support the Queensland VET sector and is intended for use as a source of ideas and options that can be adapted and customised for a provider’s unique situation. The Queensland Government disclaims all responsibility and all liability for any expenses, losses, damages and costs you might incur as a result of the information in this Guide being inaccurate or incomplete in any way, or from the use of, or reliance on, this material. Disclaimer By their very nature, Best Practice Guides are a work in progress. They are a snapshot in time of how providers are dealing with a topic and/or market opportunity. It is not possible to capture every detail regarding the subject or every provider’s experience. As a dynamic industry resource your ongoing submissions, contributions and ideas are welcomed – please email us at TAFEQueenslandinternational@ deta.qld.gov.au. 2 International Education Agent Management | A Best Practice Guide
  • 5. Industry Contributions TAFE Queensland International wishes to acknowledge the valuable insight of the registered training organisations (RTOs), education agents and other industry experts in Queensland that provided input into this Guide. These include: • AMET Education • AusEd Brisbane • Australian Council for Private Education and Training (ACPET) • CHARLTON BROWN® • City Smart Education • Gold Coast Institute of TAFE • IDP Brisbane • International Education Services (IES) • Marlin Overseas Student Agency • Metropolitan South Institute of TAFE • Migration Institute of Australia • Queensland Education and Training International (QETI) (now known as International Education and Training Unit within the Department of Employment, Economic Development and Innovation (DEEDI)) • Sarina Russo Schools Australia • Shafston • Southbank Institute of Technology • Think Education Group • Viva College International Education Agent Management | A Best Practice Guide 3
  • 6. Table of Contents Acknowledgments 2 Requests for Information 2 Disclaimer 2 SECTION ONE: AGENTS AND THE AUSTRALIAN INTERNATIONAL EDUCATION SECTOR 6 1. Introduction 7 1.1. Aim of the Guide 7 1.2. The Approach 8 1.3. How to Use this Guide 8 2. What is an International Education Agent? 8 2.1. Types of International Education Agents 9 3. Why Use an International Education Agent? 10 3.1. Reasons to Partner with International Education Agents 10 3.2. Reasons not to Partner with International Education Agents 10 4. Agent Regulation and Control 11 4.1. ESOS Act and the National Code 11 4.2. Education Agents Peak Professional Body 13 4.3. Additional References and Resources 14 5. Managing Agents in Turbulent Times 14 5.1. Potential Risks 15 5.2. Due Diligence and Monitoring 16 5.3. Managing Change Effectively 16 6. Strategically Managing Your Business 18 SECTION TWO: THE AGENT MANAGEMENT PROCESS 19 1. Best Practice in Agent Management 19 1.1. Steps in Agent Management 19 2. Identifying Agents 20 2.1. Market Alignment 20 2.2. Agent Alignment 21 2.3. Sources of Agent Contacts 23 3. Appointing Agents 25 3.1. Application Process 25 3.2. Agent Management Models 28 3.3. Contracting Agents 32 4. On-going Agent Management – Relationship Building 35 4.1. Ongoing Agent Management 35 4.2. Communication 37 4.3. Marketing and Promotion 39 4.4. Record Keeping 40 4.5. Managing Issues 41 5. Review of Agents 42 6. Exit Strategies 42 6.1. Non-Compliance 44 4 International Education Agent Management | A Best Practice Guide
  • 7. SECTION THREE: PROVIDER TOOLS AND TEMPLATES 46 1. Sample Education Agent Code of Conduct 47 2. Sample Agent Appointment Monitoring and Termination Policy 48 1. Purpose 48 2. Scope 48 3. Definitions 48 4. Actions 48 5. Agent Performance Appraisal 49 6. Re-appointment of an Agent 49 7. Termination of an Agent 49 8. References 50 9. Forms/Record Keeping 51 3. Sample Application for Consideration to be Appointed as an Education Agent 52 1. Sample of an Application Letter 56 2. Sample of Provider Information (International Prospectus) 57 3. Example of an Educational Referee Report 58 4. Example of a Student Referee Report 59 5. Process Checklist: New Agent Application 60 6 Example of Rejection Letter 61 7. Example of Education Agent Acceptance Letter 62 8. Sample Agent Contract 62 9. Example of Education Agent Certificate of Appointment 74 10. Example of Order Form for Promotional Materials 75 11. Example of Agents Manual Contents – Version 1 76 12. Sample Agents Manual Contents (ISANA Report) -Version 2 77 13. Sample of Agent Database / Register 78 14. Sample of an Agent Annual Communication Plan 79 15. Sample of Performance Review of Agent Template 80 16. Example of an Renewal of Education Agents Contract Letter 81 17. Example of Non-Renewal of Contract Letter 82 18. Example of Letter of Termination 83 4. Appendices 84 List of Acronyms 84 International Education Agent Management | A Best Practice Guide 5
  • 8. SECTION ONE: AGENTS AND THE AUSTRALIAN INTERNATIONAL EDUCATION SECTOR 6 International Education Agent Management | A Best Practice Guide
  • 9. 1. Introduction The global mobility of students has increased at a rapid rate. Over the past three decades the number of international students quadrupled, from 0.8 million (1975) to 3.3 million (2008).1 Since the late 1990s, growth has accelerated. In 2008 alone growth was 11 per cent on the previous year.2 Should current trends in international enrolments continue it is expected that between 4.1 million and 6.7 million students will be studying abroad by the year 2020.3 Australia’s share of the global international student market is between 7 and 8 per cent. Education is Australia’s third largest export industry and Australia’s largest service export, ahead of tourism.4 The value to the Australian economy of education exports in 2009–10 was $19.1 billion, an increase of 10.2 per cent on 2008–09. Educational services have grown to become Australia’s largest services export industry ahead of other personal travel services ($12.1 billion) and professional and management consulting services ($3.1 billion). In 2010 over 619,000 international students from more than 100 countries were enrolled to study in Australian institutions. The majority was in higher education (39 per cent) and vocational education and training (VET) (34 per cent). Australian institutions actively use an extensive network of commercial agents within target markets to promote their offerings and to recruit international students. Over 40 per cent of commencing international students are engaged or introduced through an agent of one kind or another.5 The use of agents has been a hallmark of Australian international education and has been instrumental in Australia’s outstanding commercial success. In 2010-11 the Australian international education sector experienced its first significant downturn and as such providers have needed to reassess the role and use of agents in their recruitment strategies. In order to maintain market share and growth in the Australian VET sectors internationally, education providers need to be increasingly savvy in their approach to business development. International education agents play a significant role in the international education sector. In fact, International Benchmarking research conducted by Alan Olsen in 2008 indicates that on average over 50 per cent of student enrolments were referred by international education agents to the Queensland public VET sector in that year. Working effectively and efficiently with agents will be crucial to ensuring the Queensland VET sector can sustain and increase its share of the international education market. 1.1. Aim of the Guide TAFE Queensland International has commissioned this research into agent good practice and prepared this Guide in order to assist Queensland VET providers in building their capacity and effectively partnering international education agents. The specific aims of the research are to: • better understand good practice in agent management and share the findings with education providers and international education agents so Queensland can continue to improve operations • build a better understanding of the roles and activities that both providers and agents play in the international education industry. 1 OECD (2010). Education at a Glance, p. 32.UNESCO (2009) estimates a total of 2.8 million international students globally in 2007. While estimates may vary, being based on different parameters, the overall trend towards significant continuing growth is evident. 2 OECD (2010).Education at a Glance, p. 32. 3 Calderon, A. (2010).Emerging countries for student recruitment in tertiary education.Paper presented to the IMHE-OECD Conference, Higher Education in a World Changed Utterly: Doing More with Less, Paris September 2010, p. 6. 4 Australian Bureau of Statistics (2010).(ABS Catalogue no. 5368.0.55.004).Note: Includes international students studying onshore on student visas only. Export income does not include income generated by the operation of offshore campuses of Australian institutions. 5 Olsen, A. SPRE, (2009) International Education Agent Management | A Best Practice Guide 7
  • 10. Based on the research this Guide has been developed to provide practical tools and techniques for providers to work more effectively together with agents to continue to achieve significant growth for the Queensland and Australian international education industry. 1.2. The Approach The approach and initial research to inform this guide was undertaken in 2009. The outcome of the research was the 2009 Agent Management Best Practice Guide, that has been very well received and highly utilised across the sector. Since this time there have been a number of changes in market conditions that have resulted in the need to review the currency and relevance of the guide content. This Guide represents an updated version of the original and provides additional and current references and resources to ensure providers maintain efficient practices. To ensure the current edition is timely and relevant the following approach was used to inform its development. Phase One: Desk Research This phase aimed to identify current practice and process in effective international education agent management through desk research. A range of articles, presentations, conference papers and international education providers’ web sites were reviewed to determine processes. Current legislation was also reviewed so that the requirements needed to inform policies and procedures were noted. Phase Two: Interviews with Targeted VET Providers and Agents Based on the research above, a discussion framework was developed for phone interviews with a targeted group of VET providers in Queensland. The targeted providers covered those at various stages of their internationalisation. The interviews aimed to identify: current agent management practice for VET providers in Queensland and what providers felt was needed to advance or improve their agent management activities. Providers were also asked to provide examples of forms, processes and resources that could be used to inform the creation of the Provider Templates found in Section Three. Phase Three: Report Preparation and Review Based on the outcomes from Phase One and Two the final report was prepared for feedback from key stakeholders. The final publication is this International Education Agent Management Best Practice Guide 2011. 1.3. How to Use this Guide This Guide has been developed in three sections: • Section One provides an overview of the international and domestic market to provide context. • Section Two outlines the steps of best practice in education agent management. • Section Three provides a set of tools, templates and resources providers can contextualise to their specific business needs. Depending on your needs, you can work through the Guide or simply choose relevant sections. Each section includes case studies to provide further information and practical examples. 2. What is an International Education Agent? An international education agent is often seen as a bridge between the many people involved in international education– including students, parents, providers and home-stay families –providing a pivotal link between them. Agents can be found across the world with many offering services to the full range of providers including language schools (ELICOS), schools, VET providers and higher education institutions. The specific activities of an agent vary based on provider and student needs, but their core activities are generally targeted towards students and providers as follows in Table 1. 8 International Education Agent Management | A Best Practice Guide
  • 11. Table 1: Core International Education Agents’ Services Targeted to Students Targeted to Education Providers • Providing information on the range of education • Recruiting suitable students for the provider options, courses and pathways • Processing student applications • Providing information on the preferred countries – travel, lifestyle, etc. • Offering a translation service • Providing market intelligence on changes to demand • Providing education counselling for students to for courses ensure the most appropriate course selection • Marketing and promoting education providers • Processing applications to education providers • Student-related administration • Processing visa applications • Supporting students while in Australia The education agent industry is not regulated in Australia. Agents are not required to be a member of any particular body, or have any specific training or minimum business requirements. However, there are a number of quality controls and systems that can assist providers in determining whether they should enter into a partnership with a particular agent. More detail on this can be found in the Due Diligence section of this Guide. It should be noted that an education agent that is not a registered migration agent cannot provide migration advice to a student but can provide advice regarding student visa types. 2.1. Types of International Education Agents There are two key types of education agents. These are: • inbound student agents • partnership agents. Inbound Student Agents Inbound student agents focus on recruiting students to study in Australia. These agents may be based either in Australia or offshore or they may have branches in a number of locations. Many agents provide services to a number of clients in markets across the world. Most often inbound student agents work on a commission per student recruited. Providers should be aware that some agents may use the services of a sub-agent – that is, an agent that feeds students through a lead agent to a provider. As the National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2007 (National Code) prescribes that all providers must have a written agreement with an agent, providers should seek clarification from any agent if this is practice and how the process is managed. This can be clarified during the agent application stage. While not common, some agents may request to be a sole/exclusive agent in a particular market. Providers should carefully consider the pros and cons of such an agreement and ensure they are not limiting their options. Partnership Agents/Business Brokers These agents focus on developing partnership programs between international providers and/or industry. Often these agents work on a retainer or commission per project. International Education Agent Management | A Best Practice Guide 9
  • 12. Migration Agents vs. Education Agents A migration agent is an individual who has met the minimum requirements to be registered with the Migration Agents Registration Authority (MARA). This registration allows them to legally provide immigration assistance and advice. For more information and a list of Australian registered migration agents visit https://www.mara.gov.au. Many migration agents also offer the services of an international education agent and vice versa. Agents with both the education and migration skill and knowledge in their organisation may add value to an agency partnership. Providers should ensure they understand the primary focus of the agency and their strengths as different management styles and approaches may be needed for agents with different skill sets. For example, a migration agent may need more support in educational knowledge, such as knowledge of Australian Quality Training Framework (AQTF) or the Education Services for Overseas Students (ESOS) Act 2000. 3. Why Use an International Education Agent? The international education agent industry is highly competitive and working with a good agent can be very lucrative for an education provider. While this is the case, the decision to employ an education agent should be considered carefully to ensure agents are used most effectively for your organisation. There are a number of reasons you may consider using an education agent and a number of reasons you may not. These are described below. 3.1. Reasons to Partner with International Education Agents • Agents can provide innovative marketing and promotional ideas that may be highly relevant to the target country. • Agents with offices or contacts in offshore markets can provide first-hand information on trends and opportunities. • Agents with offshore offices can provide on-ground support and thus reduce the need to travel as frequently to markets, reducing the overall business development costs and increasing profitability. • Agents provide local expertise and have local language and cultural understanding and knowledge. • Agents can provide access to high-risk markets that may be costly, difficult or dangerous to access. • Agents can provide a one-stop-shop for students, which may increase students’ overall satisfaction with the experience. 3.2. Reasons not to Partner with International Education Agents • Agents are not regulated in Australia and as such a greater onus is on the provider to select quality agents. • Under the ESOS Act there is a requirement to manage agents and adhere to minimum management requirements, using staff resources that could be used for other activities. • The industry standard commissions paid to agents are significant and providers need to assess these costs against direct student recruitment. • Agents are placed in a position of considerable power, being the business development arm for your organisation, and therefore providers need to manage and control their activities. • There is potential for providers to be targeted by agents that employ illegal and/or unscrupulous practices, so considerable due diligence is required. 10 International Education Agent Management | A Best Practice Guide
  • 13. 4. Agent Regulation and Control 4.1. ESOS Act and the National Code The National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2007 The National Code as it relates to the use of education agents requires that providers: • use education agents with an appropriate knowledge and understanding of the Australian international education industry • enter into a written agreement with agents you engage to formally represent you • ensure your education agents have access to up-to-date and accurate marketing information • do not accept students from, or enter into an agreement with, any agent you suspect to be engaging in dishonest practices • terminate an agreement if you become aware that your agent is acting dishonestly or unethically • take immediate corrective or preventative action if you become aware of any form of unprofessional activity by your agent. 2010 Amendments to the ESOS Act In 2010, following a review of the ESOS Act, new regulations were introduced in order to improve the accountability in the use of agents. Under the Education Services for Overseas Students Amendment (Re-registration of Providers and Other Measures) Act 2010, providers are required to ‘maintain on their website a list of all persons (whether within or outside Australia) who represent or act on their behalf in dealing with overseas students or intending overseas students’. Further proposals were outlined in the ESOS Act review and, if introduced, providers will need to comply. Providers will need to keep abreast of these possible changes in the future. Suggested amendments include: • holding providers more accountable for agents –providers could be fined if their offshore agents act unethically • banning Australian-based agents from charging commissions for luring students from one local college to another • banning providers from paying commissions to agents unless they disclose the identity of the agents and their commission arrangements to both students and regulators • implementing a ‘unique identifier’ to track the colleges attended by each student • taking some form of direct regulatory action against offshore agents, such as preventing them from applying for visas on behalf of their clients, if they fail to meet legislative requirements. The Government’s final position on the regulatory changes will be informed by proposed consultation and the feedback received. International Education Agent Management | A Best Practice Guide 11
  • 14. POLICY - Standard 4 – Education Agents National Code, Standard 4 (Education Agents): Registered providers take all reasonable measures to use education agents that have an appropriate knowledge and understanding of the Australian international education industry and do not use education agents who are dishonest or lack integrity. 4.1 The registered provider must enter into a written agreement with each education agent it engages to formally represent it. The agreement must specify the responsibilities of the education agent and the registered provider and the need to comply with the requirements in the National Code. The agreement must also include: a. processes for monitoring the activities of the education agent, including where corrective action may be required, and b. termination conditions, including providing for termination in the circumstances outlined in Standard 4.4. 4.2 The registered provider must ensure that its education agents have access to up-to-date and accurate marketing information as set out in Standard 1 (Marketing information and practices). 4.3 The registered provider must not accept students from an education agent or enter into an agreement with an education agent if it knows or reasonably suspects the education agent to be: a. engaged in, or to have previously been engaged in, dishonest practices, including the deliberate attempt to recruit a student where this clearly conflicts with the obligations of registered providers under Standard 7 (Transfer between registered providers). b. facilitating the enrolment of a student who the education agent believes will not comply with the conditions of his or her student visa c. using Provider Registration and International Students Management System (PRISMS) to create Confirmations of Enrolment for other than a bona fide student, or d. providing immigration advice where not authorised under the Migration Act 1958 to do so. 4.4 Where the registered provider has entered into an agreement with an education agent and subsequently becomes aware of, or reasonably suspects, the engagement by that education agent, or an employee or sub-contractor of that agent, of the conduct set out in Standard 4.3, the registered provider must terminate the agreement with the education agent. This paragraph does not apply where an individual employee or sub-contractor of the education agent was responsible for the conduct set out in Standard 4.3 and the education agent has terminated the relationship with that individual employee or sub- contractor. 4.5 The registered provider must take immediate corrective and preventative action upon the registered provider becoming aware of an education agent being negligent, careless or incompetent or being engaged in false, misleading or unethical advertising and recruitment practices, including practices that could harm the integrity of Australian education and training. 12 International Education Agent Management | A Best Practice Guide
  • 15. 4.2. Education Agents Peak Professional Body Prior to 2011 there was no formal monitoring or control of international education agents at a systemic level; the onus was on the provider to ensure an agent’s standing. In April 2011 the Migration Institute of Australia (MIA) extended membership in the peak body for the migration advice profession to qualified, registered education agents. It is not mandatory for an agent to be a member of MIA. Membership, however, could be used as one of the criteria to determine if an agent is a suitable partner. The MIA has established a Code of Ethics for Affiliate Education Agents. This Code describes the requirements that agents must adhere to in order to hold membership. Affiliates must agree to: • continually strive towards lifting the standard of education Agents within the Australian and international communities • act at all times in a manner that upholds and enhances the integrity and dignity of those working within the international education environment • be open and honest with clients at all times in regards to the scope of services available • inform their clients that as per the Migration Act, they cannot provide migration advice (unless also registered as a Migration Agent) • commit to ongoing professional development throughout their career and actively assist and encourage their fellow members to advance their professional knowledge and experience • comply with the relevant Acts, Regulations and MIA Code of Conduct when dealing with clients • make no representation regarding the provision of services that are false or misleading and to fully disclose all applicable charges for services, as well as the scope of the services to be provided prior to engaging a client • recognise and respect the rights, dignity and individuality of all persons. A member shall not discriminate or knowingly permit discrimination on the basis of race, national origin, sex, sexual orientation, religion, age or disability • avoid conflicts of interest at all times with regard to professional activities, financial considerations or other interests. At such time as a member becomes aware that an actual, apparent or potential conflict of interest exists, the member must make a full disclosure to the appropriate parties. For more information visit: http://mia.org.au/educationagent/. Agents have also established professional peak bodies within their own countries. Each of these professional bodies has its own code of ethics and can be used as a tool in collecting due diligence information. International Education Agent Management | A Best Practice Guide 13
  • 16. 4.3. Additional References and Resources As shown in Table 2, a number of publications and resources have been developed to assist providers to understand and implement the requirements under the ESOS Act and National Code. Table 2: Agent Management Resources Publication Source Education Agents Manual International Student Association New Zealand http://www.isana.org.au/files/EducationAgentsManual.pdf and Australia (ISANA) Best Practice in Education Agent Management Victorian TAFE International (VTI) http://www.aei.gov.au/Regulatory-Information/Pages/Regulatoryinformation.aspx Using Education Agents, A guide for providers of education and training to overseas Department of Education, students Employment and Workplace Relations (DEEWR) http://www.pieronline.org/_Upload/Files/Using_Education_Agents_pdf.pdf National Code Explanatory Guides Australian Education International (AEI) http://www.aei.gov.au/Regulatory-Information/Pages/Regulatoryinformation.aspx 5. Managing Agents in Turbulent Times In 2010 the Australian international education sector experienced its first significant downturn. Figures reported by providers range from a 10 to 30 per cent reduction in student enrolments in 2010 alone. The downturn has been attributed to a combination of external factors such as; • the global financial crisis, • increased international competition and the appreciation of the Australian dollar, • and domestic factors such as changes to student visa requirements, student safety concerns, changes to the skilled migration program and the commercial failure of a number of colleges. Reports indicate that the impact of the downturn was felt across the whole sector and is continuing to be felt. In turbulent times providers many need to place greater emphasis on: • being aware of possible risks and unethical practices • ensuring effective due diligence and monitoring processes are in place • managing change effectively. 14 International Education Agent Management | A Best Practice Guide
  • 17. 5.1. Potential Risks The relationship between economic downturn and increased illegal activities is well reported. While we know most agents are honest, reliable and are looking for a mutually rewarding partnership, it is more likely in difficult times for individuals to take advantage and attempt to gain from illegal behavior. As such it is advisable for providers to make themselves aware of possible illegal practices that could affect their business and have strategies in place to pre-empt these. It should also be noted that these activities can occur from inside your organisation as well as outside. The set of case studies below provides a good summary of possible fraudulent activities that have been reported across the sector. CASE STUDY : Examples Of Rouge Agent Activity International Draft Scam – A prospective international student approached a provider to enrol as a student. An international draft for tuition fees was forwarded, payable to the provider. The draft was banked. A number of days later the international student contacted the provider advising that due to a family tragedy they would no longer be able to attend the provider and consequently requested a refund of the fees already paid (the figure was close to $10,000). The staff became suspicious and looked into the request. Meanwhile the bank contacted the provider to advise that the draft had been dishonoured and appeared to be fraudulent. Clearly the intent was to have received the refund prior to the provider being notified of the fraudulent draft. Web Scams – In Country Y, where Provider X was operating, an agent set up a website with the URL http://www. providerX.countryY.com. The website linked directly to the agent’s own website. Suddenly the other agents in Country Y started to complain because it looked like this was the ‘official website of Provider X’, directing the enquiries straight to the agent. The other agents assumed the agent was getting preferential treatment but in fact he had simply purchased the URL and used it for his own purpose. There is nothing illegal in his action. It does, however, compromise Provider X who went to great lengths to ensure the agent change the website and stop using the provider name in the URL. The agent complied and they are still partners. Another agent set up a website using information and logos of multiple Universities creating the impression that this agent represents these institutions. None of the Universities have a formal relationship with this agent. Because the agent is not an authentic agent, there is little the Universities can do about the problem. It has proven difficult to protect the logos from being downloaded or used in electronic forms. Double Dipping Scam – An agent was accused of double dipping on commissions. He sent a second invoice for the same student, in the same course. The provider had a system of paying on invoices for multiple students with a grand total. They did not have a clear way of recording against the student’s name what was paid and when. The second commissions were paid. The agent did it accidentally in the first instance but when it wasn’t discovered they tried again successfully and then, of course, it became a lucrative habit. It was exacerbated by the fact that sometimes the invoices would arrive months after the student had commenced and the provider was not good at tracking its payments over time. A response to this was to set up a new system with a unique invoice number for each student. This has resolved the problem. The provider was also concerned that perhaps one of the staff who had sole responsibility for paying commissions may have been working by prior arrangement with the agent. An audit by an outside consultant identified that a key risk to the Provider was having a single person responsible for this commission payment task. Conflict of Interest – A Provider’s marketing staff person asked permission to sign up a close relative as an agent. At no stage did they alert the Provider that the agent was related to them even though the agent was operating in their marketing region and there was a conflict of interest. The scam was discovered but the staff person claimed to be innocent of all knowledge of how this could have happened and told a range of increasingly unbelievable stories around the matter, consistently denying a conspiracy. Only after extensive investigation and confrontation, involving the Provider’s Human Resources section, the Unions and provision of irrefutable written evidence did the staff person accept there was something untoward. At this point, even though the saga had drawn out over two months, the person’s last resort was to claim that the relative had misled them and that they were shocked and appalled. The staff person was married to the agent and lived with them at the business address. Theft – An agent took a non-refundable up front payment from all students for the services that the universities provide free –for example, airport pickup, orientation and accommodation support. Modified from Scams and Scammers: Agents and the International Office. A Cautionary Tale, Virginia Pattingale, http://www.aiec.idp.com/pdf/Paper_Pattingale.pdf International Education Agent Management | A Best Practice Guide 15
  • 18. 5.2. Due Diligence and Monitoring The process of conducting due diligence and ongoing monitoring and evaluation are a feature of this Guide. Section Two of this document provides detailed processes and questions for providers to support their agent selection and management. In addition to this resource, providers can also refer to the Partnership Due Diligence Best Practice Guide. 5.3. Managing Change Effectively The aim of this Guide is to provide strategies and tools to ensure your systems and processes are the most efficient and effective they can be. Even if you adopt and apply all the best practice ideas outlined, at times your business will be exposed to economic and social conditions that are outside your control. As such, providers will need strategies to ensure your business can be sustained through changing conditions. In turbulent times providers should focus attention on activities such as: Agent Mix • Review the number of agents you have on your books and your ability to effectively service these. It might be that you need to reduce the number of agents you have and provide more focused attention to a few. • Which agents are you working with that provide the best returns and outcomes? Consider the 80/20 rule and actively work with your top agents to ensure their needs are met and they are satisfied. • Review the role and services an agent offers. Market Strategies • Review your market diversification. It is important to get the right balance between having sufficient source markets to generate enrolments and your ability to service them. Service Levels • Ensure your service levels for administration and course delivery remain very high. Agents will be more demanding of providers and be looking for the best product and offering for their clients. By maintaining and ensuring a high quality the reputation of your brand is retained, which will support future enrolments. Coordinating with Agents • Invite your agents in and discuss the current environment. Consider mutual ways you can work collaboratively to maintain business. • Ensure you maintain regular and engaging communication with your agents. Communication is key to any relationship and a solid relationship will lead to enrolments. If face-to-face communication is prohibitive due to cost, consider lower cost communication channels such as social networking platforms, Skype and email. Consider Pricing Strategies • Carefully consider your pricing strategies. In poor economic times discounting is often used to attract business. While this may help business initially it potentially can reduce the perceived value of your courses and services. • Monitor your commission rates and negotiate these wisely. As part of your negotiation with agents you may consider increasing your commission provided to agents to be competitive. It is very difficult to reduce commissions once you have increased it. It may be more appropriate to consider other incentives. Providing part scholarship per x enrolments may be a low cost option if your fixed costs are met for a particular course. 16 International Education Agent Management | A Best Practice Guide
  • 19. Creative Promotion Strategies • Consider joint promotions with other providers in a promotion consortium to reduce marketing costs. This could include shared offshore agents visits. Monitor and Review • It is important to use monitoring activities to know your position and adjust your strategies as required. Section Two of this Guide provides detail on these activities and a step-by-step guide to managing your agents. International Education Agent Management | A Best Practice Guide 17
  • 20. 6. Strategically Managing Your Business Strategic management is a key element in the success of any business or project. The purpose of this Guide is to provide practical advice and tools to optimise the provider–agent relationship. It is important to understand your organisational objectives, operating environment, and identifying strategic activities. This understanding leads to establishing a transparent document that can be adopted by the whole institution to drive successful provider–agent projects. Identifying, appointing and managing agents should be identified as a key strategic activity for your organisation. Figure 1: Agent Management within a Strategic Framework IDENTIFY AGENTS based on › Organisational Objectives › Market Objectives ORGANISATION INTERNATIONAL STRATEGIC PLAN ORGANISATION PLAN Financial Management Plan Organisational Plan SELECT AGENTS Marketing Plan Conduct Due Diligence Contract/Agreement Agent Management Review Exit • the types of agents are identified on the basis of your organisational and international objectives. This should be considered and finalised during the strategic planning process. What kind of agent do you need to appoint in a particular market to assist in meeting market objectives? • Agents are selected on the basis of ‘best fit’ in meeting your goals in a particular market. Does the agent being considered offer skills and services that are needed to meet market objectives? • Agent management is built into your international plan and internal management model with: -- internal positions/staff designated for the ongoing identification, recruitment, management and review of your agent network -- information management systems identified for the ongoing monitoring and record keeping involved in managing agents -- the costs of managing agents included in your financial management plan. 18 International Education Agent Management | A Best Practice Guide
  • 21. SECTION TWO THE AGENT MANAGEMENT PROCESS 1. Best Practice in Agent Management 1.1. Steps in Agent Management Five key steps have been identified as best practice to ensure effective agent management. The process is cyclical with ongoing identification, management and review occurring at different times depending on the business needs, market conditions and agent activities. These five steps are: Identify Appoint Manage Review Exit Figure 2: The Agent Management Process 3. ONGOING AGENT 1. IDENTIFY AGENTS MANAGEMENT assess internal needs conduct initial training identify agent conduct refresher training develop communication approach 2. APPOINTING AGENTS agent completes application 4. REVIEW OF AGENTS conduct due diligence review performance decide on approach to service provision re-negotiate performance requirements agree on terms of business re-sign contract agree on performance indicators develop contract 5. EXIT STRATEGIES provide certificate of appointment terminate contract if required forward student appeal information packs International Education Agent Management | A Best Practice Guide 19
  • 22. Identify Appoint Manage Review Exit 2. Identifying Agents There are numerous types of agents and hundreds of different businesses operating as agents internationally and locally. If you are a large, well-established provider to international students, in many instances agents will seek you out. Smaller providers however, or those new to the international education industry, may have to actively search for agents to appoint. No matter which category your organisation falls into you need to have a clear understanding of agents and their role in each market. You should consider: • market alignment – the market objectives and client needs that the agent will service • agent alignment – your business needs or objectives that the agent will service. Investigating these questions at a macro level will assist in identifying agents that align with your business needs and objectives in a market as well as market-specific issues that may need to be addressed. 2.1. Market Alignment Every market is different and should be approached in a unique way. Agents may have different roles, offer different services and operate at different levels of accessibility in different countries. You need to research the market in the context of the needs of the students and the services offered by agents, as well as other market issues such as visa processing, the relationship between agents and governments, and regulation of agents. In investigating the market you should consider the following: • Is the use of an agent an effective market strategy to meet your organisational objectives? • What are the particular market trends? Are they whole-of-country based or regionally based? Large countries such as India, China, and Russia have niche regional markets and may require different strategies and agents to be employed in each one. In other markets, such as Scandinavia, it is the ‘done thing’ to employ and work closely with only one agent. The Scandinavian market, although covering several countries, tends to be more similar than many regional markets within the same country. • Where is Australia placed competitively in the market? Is Australia’s market share large or small? Does this affect the agent–provider relationship? For example, in Malaysia and China there may be agents that focus solely on Australia because of the size of Australia’s market share. In other countries, such as Russia, Australian agents will service a number of different markets so providers may have to maintain these agents more to gain some competitive advantage. • Are there any particular market issues affecting agents? For example, in countries where there is a high corruption index this may affect a particular agent’s ability to process student visa applications or affect your management of an agent. • Are there any in-market government regulatory requirements concerning agents? • More agents are employing an ongoing-care strategy with students, which does not necessarily end when their commission is paid. Agents sometimes provide support, advice and services prior to, during and following students’ first qualifications. Investigating these areas and others will help you build a profile of agents’ roles in each specific market and assist you in targeting your search if you do identify agents as a key strategic activity. 20 International Education Agent Management | A Best Practice Guide
  • 23. Approaches to Agents by Market Working with agents requires a unique approach for each market to ensure the local needs, regulations and customs are adhered to. It is recommended that the legal, financial, institutional and cultural considerations be addressed for each market in which you intend to work. Understanding and flexibility are required. It is also important to consider the timing adopted for each market. As outlined in Table 3, education and training dates vary for different markets. Table 3: Indicative timing of key term dates for selected markets Market Term 1 Term 2 Term 3 Term 4 School Year Finishes Australia February April July October December North & Central America September December February April July Continental Europe August October January April June Japan April September January - March South America February April July October December Implications for agents: • Have material ready. • Negotiate the strategic use of conditional offers to fit into timing – i.e. give a conditional offer on the basis of incomplete results. • At peak times make sure providers are well resourced. Resource planning is necessary. • Have appropriately trained staff – for example, culturally aware staff. CASE STUDY : Education Agent Requirements by Market The Chinese Government introduced laws to regulate the activities of agencies providing advice to Chinese students about going overseas to study. These laws regulate the activities of student recruitment agencies in China, not students or overseas institutions. The laws require agencies to be registered with the National Government, via a process of nominations from provincial/municipal authorities. No foreign organisations are permitted and unapproved agents are prevented from advertising. The laws prevent agents from actively recruiting students at secondary schools (children under 15 years of age). There are nearly 400 agents approved by the Chinese Ministry of Education. A full list of approved agents is available to purchase from Austrade Beijing. Providers seeking to deal with agencies that claim to have national approval should refer to this list. More information can be gained through Austrade in China. 2.2. Agent Alignment Assessing the market will provide you with a clear understanding of whether your business objectives will be met by appointing an agent in-market or whether other strategies would be a better use of resources. It will also provide you with information to select agents that align with your objectives in-market, specifically: • the type of agent required in-market • the client maintenance expectations of the market, which will determine whether you should appoint an agent onshore or offshore • how agents monitor the market trends and demand for your product and how competitive the market is • the number of agents needed to service the country, given regional niche markets. Does each region require a different agent or can one agent, through their networks, service the whole country? International Education Agent Management | A Best Practice Guide 21
  • 24. Onshore vs. Offshore Many agents have offices based in Australia to provide ongoing service for their students and to establish a stronger relationship with providers. Most Australian-based agents have affiliated companies based in their target market. They usually travel offshore to recruit students on your behalf. The advantage of an onshore agent is that they have a high level of accessibility to you and your organisation. An offshore- based agent, however, may have more accessibility to in-market information and potential partners. An agent who has a large network both in Australia and offshore would have both benefits. You may need to monitor the legislative changes to the ESOS Act. One recommendation that has been made is to require more accountability for onshore agents, such as banning the payment of commissions should an onshore agent be caught poaching students from one provider to the other. As shown in Table 4, a simple matrix of the markets you wish to target and the number of agents you have servicing that market can help you manage and plan the search for agents. Note that markets can be as dynamic as they are diverse, so an agent environmental analysis should be conducted regularly to ensure your agent management strategy is following market trends. Table 4: Market–Agent Matrix Market No. of Students Target No. of Agents Contracted No. of Agents Needed China 30 0 2 Japan 20 2 1 India 50 3 4 Total 100 5 7 Quality vs. Quantity It is important to know your agent market and plan as much as possible. However, the decision to appoint a certain number of agents in a market is not always a strategic one. There are generally two approaches within industry to selecting and appointing agents: • appointing a minimum number of agents with whom you build quality relationships. These agents usually refer large numbers of students to your institution. • appointing a large number of agents in a market. This strategy involves appointing several agents who each refer small numbers of students to your institution. Collectively they make up your country enrolment target. It is much more difficult to manage large numbers of agents effectively or to build strong sustainable relationships in using this strategy. There are benefits to each approach. It is probably a natural progression that a smaller VET provider, starting out internationally, would initially appoint a larger quantity of agents. As they grow and establish strong relationships with key agents, they reduce the number of agents working with them. This progression is not always strategically driven: as an organisation grows internationally and establishes a brand in-market this places them in a better position to negotiate and establish a quality relationship with the more successful agents in-market. 22 International Education Agent Management | A Best Practice Guide
  • 25. CASE STUDY : The Changing Nature of Agents IDP Expands to Recruit for Alternate Markets IDP Education has become the world’s largest student placement firm, operating more than 70 counselling centres in more than 20 countries and placing more than 300,000 students. It was jointly owned by 38 Australian universities and a leading online recruitment firm. IDP has been placing students into Australia for more than 20 years. In 2009 the organisation expanded into the United States and since that time has built the largest portfolio of university partners of any agency worldwide. IDP has now further expanded into the United Kingdom, Canada and Turkey and is continuing its growth into a multi-source, multi-destination placement organisation. 2.3. Sources of Agent Contacts International education agents can be found in countries throughout the world and there are many ways providers can identify suitable agents. It is now a requirement under the ESOS Act for all Australian providers to list their agents publically on their website. While this can be a good source of potential agents, providers should always conduct their own due diligence on these agents to ensure they are strategically aligned to your business. Table 5 provides a summary of some possible sources of agents you may consider. Table 5: Sources of Agent Contacts Source Description Austrade http://www.austrade.gov.au/ International Education ICEF: http://www.icef.com/ Agents Fairs (ICEF) Local onshore Agents Trade Queensland Australian-based, country-specific associations: for example, the Singapore Malaysian Association of Australia telephone books Chamber of Commerce and Industry other providers Internet web searches Networking with other other registered training organisations Providers other sectors Web search Provider Agent published provider lists of educational representatives either on their websites Lists or through their international prospectuses International Education Austrade Fairs Student Fairs Queensland Government http://www.export.qld.gov.au/contact-us.html#international Offices Offshore International Education Agent Management | A Best Practice Guide 23
  • 26. Professional International www.pieronline.org. Education Resources (PIER Online) for a full list of Qualified Education Agent Counsellors: http://www.pieronline. org/qeac/mobile.aspx Direct to you Internet site Offshore providers and agents introduction via networks in different markets Advertising expressions of interest/tender Agent Associations Migration Institute of Australia (MIA) http://mia.org.au/educationagent The Federation of Education and Language Consultants has a world wide network of Agents Associations (FELA): http://www.felca.org/ Association of Australian Education Representatives in India (AAERI): http:// www.aaeri.org/ 24 International Education Agent Management | A Best Practice Guide
  • 27. Identify Appoint Manage Review Exit 3. Appointing Agents At this point you have assessed the market, identified the use of agents as a key recruitment strategy, and determined the type of agents you require. You now need to select specific agents to implement your strategy. Appointing and using agents as a recruitment strategy can be very effective; however, it is not without its risks. It is essential that appointed agents act ethically and professionally. From a marketing point of view agents are generally the first point of contact clients have with your organisation. A bad first impression can damage your in-market reputation. Also, there is a legal obligation through the National Code for providers to ensure that agents are honest. A number of providers have developed an Agent Code of Conduct as a public means to articulate their requirements for agents. Proposed amendments to the ESOS Act as described in the Baird Review will place greater onus on the provider to manage agents. As such it is important that you state your expectations up front. It is advised that your Agent Code of Conduct is placed on your website for easy access. POLICY : The National Code (2007): Standard 4 – Education agents, Outcome of standard 4 Registered providers take all reasonable measures to use education agents that have an appropriate knowledge and understanding of the Australian international education industry and do not use agents who are dishonest or lack integrity.67 3.1. Application Process The appointment of an agent involves three steps: 1. Undergoing due diligence through an application process 2. Establishing the kinds of agent management models you are going to use 3. Formalising your partnership through a contract. To reduce the risk associated with partnering with a non-desirable agent, many providers have implemented an application process during which due diligence of the agent is conducted. The application process is also an opportunity to identify agents best suited to your organisation’s needs in the market: you can find out how far their networks reach and potential market strategies they are going to implement. It is recommended that your agent application form be divided into four sections: • Due diligence – where the corporate profile, organisational structure and referees are established • Training and educational qualifications – where potential agents’ knowledge of the Australian education industry and training qualifications is established • Market information – where knowledge of the target market, services being offered and in-market strategies are established • Services they will offer. 6 http://aei.gov.au/AEI/CmsTemplates/GeneralTemplates/LandingPage.aspx?NRMODE=Published&NRNODE GUID=%7b2F9C1196-4B2B-49A8-A64A-67B003520F81%7d&NRORIGINALURL=%2fAEI%2fESOS%2fDefault. htm&NRCACHEHINT=ModifyGuest 7 http://www.aei.gov.au/AEI/ESOS/NationalCodeExplanatoryGuide/PartD/Standard_4.htm International Education Agent Management | A Best Practice Guide 25
  • 28. 3.1.1. Due Diligence The main purpose of due diligence is to ensure the agent you are appointing is honest and professional. There are two reasons to conduct due diligence on any potential agents: • Under Standard 4 of the National Code, providers must not make an agreement with an agent who has been engaged in dishonest and unethical practices or who has provided unauthorised migration advice. • Agents are usually the first point of contact between you and your potential students. The agent’s professional conduct is essential to maintain the integrity of your reputation as well as, more generally, Australia’s reputation as a quality provider of international education. You should thoroughly investigate the potential agent before appointing them. Most due diligence can be conducted through use of an application form, filled out by the agent, and contacting referees. Information sourced directly from the agent should collaborate with other sources such as government agencies, referees, agent associations and networks as well as your own industry networks. Areas for consideration in due diligence are: • the company profile • the owners and executives involved in the company. Pay particular detail to establishing whether anyone connected with the company has been involved in any bankruptcies, legal proceedings or liquidations • any sub-branches or affiliated companies, if the company is registered • the company’s financial probity • how long the company has been established • at least two educational referees, preferably Australian-based • possibly two student referees to ascertain the level of service the agent provided them, although this is not common practice within the Australian international education industry. 3.1.2. Training and Educational Qualifications This section of the application form should establish the agent’s knowledge of the Australian education industry. It should assess: • their familiarity with the Australian Department of Immigration and Citizenship (DIAC)—the visa application process and where to find changes to student visa requirements • their familiarity with the ESOS Act and associated National Code through the Department of Education, Employment and Work Relations (DEEWR) website • whether they are Qualified Education Agent Counsellors (QEAC). The Education Agent Training Course (EATC), delivered online by PIER is the result of collaboration between Australian Education International (AEI), DIAC and Australian international education peak bodies. The EATC covers four areas: Australia, the Australian Qualifications Framework (AQF) and career trends; Legislation and regulations; Working effectively in international education; and Professional standards and ethics. Qualified agents are listed on the Qualified Education Agent Database (QEAC) at http://www. pieronline.org/qeac/default.aspx. • whether they are qualified Migration Agents under the Migrant Act. If not, do they understand what they can and cannot promise regarding Australian residency? 26 International Education Agent Management | A Best Practice Guide
  • 29. • whether they hold any other relevant memberships or licenses. For example, you would ask agents from China to provide a copy of the Chinese Ministry of Education Registration Certificate with the agent registration number; alternatively, if the agent is based in Australia, ask for evidence that they are partnering with a registered Chinese education agent based in China. • whether they are an affiliate member of the Migration Institute of Australia (MIA). 3.1.3. Market Information The application should also allow agents to show their knowledge of their geographical territory or market. Ask for details of: • the potential market • the geographical area the agent will service and how they will service it • the agent’s strengths in these areas • the number of students they handle each year • their proposal for promotion and marketing in the territories, including the events they will organise and attend on behalf of your organisation. 3.1.4. Services Finally, you should ask for details of the services the agent is prepared to offer as part of the agency agreement. The range of services will depend on the type of agent, their qualifications, market demand and the facilities they have in country. All agents should offer the following services as a minimum: • undertaking basic promotion and marketing • providing information to prospective students on your courses, campus, facilities and other information required under Standards 4 and 5 of the National Code • assisting in the recruitment of prospective students by providing advice on completing application forms and submitting them to your organisation • arranging for English language testing of prospective students • assisting prospective students with completing and submitting Australian immigration visa applications with the Australian Embassy. Additional services may be negotiated depending on the market and the agent’s qualifications and licenses. For example, if the agent is located in Australia and is registered as an official migration agent they may be able to provide a migration advisory service to the student. If they are a travel agency they can organise airfares and accommodation in Australia. If one of your goals is to form partnerships in the target market some agents may act as a partnership broker between you and other overseas institutions. Services can be defined in more detail within the agreement. However, the application form will provide some information on the potential services the agent could offer. Note: The most successful agent–provider relationships are based on mutually beneficial and equal partnerships. Therefore it is important to provide information on your organisation to the agent when asking them to complete the application form. You should also encourage them to complete their own due diligence process on you. The partnership will only work if there is a genuine alignment of business objectives and ethos. The best way to establish the scope of an agent’s services and market knowledge is to ask for a promotion and marketing plan for their specified territory. The plan could be seen as a Capacity Statement demonstrating what the agent knows, will do and can do to meet your business objectives. It should cover the following: • This is what we know about you. • This is our understanding of your needs. • These are the services we will provide you to assist in meeting those needs. International Education Agent Management | A Best Practice Guide 27
  • 30. 3.2. Agent Management Models After identifying an agent you want to appoint, and before contracting them, you need to decide on the scope of their appointment, specifically: • the service provision—what roles and responsibilities will they have? • commission structures—how will they be remunerated? • incentive Management Models—are there rewards for exceeding goals and obligations? 3.2.1. The Service Provision What services will the agent offer? What role will they play in promoting, marketing and recruiting for your organisation? The roles and responsibilities should be based on your business’s strategic objectives and priorities. You should keep in mind why you are appointing the agent in that particular market and the services the agent offers, and align the service provisions accordingly. If the agent is newly appointed, you may wish to enlist them to provide only minimum services to the market. As the relationship grows you could increase the service provision. You should note that the more high-level services you require, the more your responsibilities towards the agent will increase, such as training, monetary support and time. Table 6 below shows suggested service provisions and examples of the level of service that an agent may offer. Table 6: Service Provision and Level of Agent Support Services Basic Intermediate High Promotion Easily available and Joint promotions such as Regional advertising accessible in shop front. interviews when provider is campaigns; agent in market. representing provider at events. Marketing None. Translating marketing Exclusive marketing plan material. organised by the agent including marketing events Provider involvement in the and advertising. agent’s marketing plan. Market Research Basic information on market New market trends and Follow-up in market for features. demands as they come to students who have not light. converted into enrolments. Customer Student Counselling. Advice on migration and visa Issuing offer letters and Service application (if the agent is a Confirmations of Enrolment Advice on educational registered Migration Agent). (COEs) on behalf of application. provider. English language testing. Assistance with visa application. Pre-departure orientation. Alumni None Alumni events and follow up. Maintaining in country alumni database. Business None Introduction and advisory Partnership brokering and Development service for partnerships in negotiation on behalf of education and industry. provider. Servicing for None Through regional events and Through regional offices regional areas promotion. and sub agents. 28 International Education Agent Management | A Best Practice Guide
  • 31. Remember that, as in any relationship, you need to build trust with the agent and the agent with you. Only appoint agents for services you are comfortable with them performing. As the relationship develops the service provisions can be changed and expanded. 3.2.2. Remuneration The most common way for the remuneration of agents is through payment of a commission. The agent is paid a percentage of the tuition fee once the student has paid their fees and commenced their studies. The industry standard varies but feedback from VET providers indicates that commission rates on average are 15 per cent for a formal qualification and 20 per cent for ELICOS.8 Some organisations, in an effort to gain the competitive advantage over other providers, have offered up to 40 per cent commission. Careful consideration needs to be given to the long-term economic viability of this approach, as opposed to using that money in marketing support for the agent. The biggest advantage of payment by commission is that the agent does not get paid if they do not recruit any students. However, a disadvantage is that, usually because agents work for a number of different providers, if they are recruiting large numbers for your competitor there is no incentive for them to re-route those students to your organisation. They get paid either way. Other payment models include: • set fee per student. • retainer. The agent is contracted to represent your organisation over a specified period of time to recruit students. It is recommended that this type of financial model be used more as a consultancy contract for a specific objective rather than a long-term market strategy. • agent administrative fees. The agent charges the students a fee. This is usually packaged and may include tuition fees, air flights, accommodation, etc. This method of payment is rarely used. However, some agents do charge the institution a commission fee and the student an administrative fee. You need to clarify whether an agent is charging students fees in addition to your commission payments. If they are, what added value are they providing the students? Associating yourself with an agent who is fleecing extra money from students can damage your reputation as well as expose you to non-compliance of the ESOS Act. It is essential you are clear on your agent’s services and payment methods. When considering which model to use, look at the environment and assess which model would provide you a competitive edge while taking into consideration the long-term effects of any strategy you employ. One strategy employed by a number of organisations is to couple the payment of a basic commission with an Incentive Management Model. 3.2.3. Incentive Schemes As the international education industry becomes increasingly competitive, agents are a major source of student recruitment for providers. To manage agents more strategically, reward agents who are working well and gain a competitive advantage over competitors. Many organisations are using incentive schemes. Incentive schemes can take many forms and may include financial or non-financial incentives. Types of incentive schemes include: • discounting. Agents are offered reduced tuition fees for the students they recruit. Discounting is used by some providers to encourage the agent to route the students to their organisation rather than a competitor. Careful thought needs to be made before offering this incentive. Discounting can seriously undermine your position and attract students who are not necessarily part of your target market. Discounting can lead to a reduction in the quality of student being referred and devalue your courses. 8 Feedback collected during consultation with Queensland VET Providers. International Education Agent Management | A Best Practice Guide 29
  • 32. • variable commission rates. Additional percentages of commission rates are included as an incentive for your agent to perform better for you. For example, if they have completed the EATC they get an additional 1 to 5 per cent commission above their basic rate. This can be an effective tool to encourage your agent to perform better services for you. However, effectiveness will depend on the agent, the size of your organisation, and the number of students the agent is sending to you. This strategy may be less effective for smaller organisations where the number of students being sourced through one particular agent can vary significantly. • scholarships. Scholarships are offered to high-performing agent counsellors in the form of Certificates, Diplomas, short courses or even the EATC. These can be particularly effective for building relationships between you and the agent. Offering a scholarship or other professional development opportunity will also increase the skills and knowledge of your agent. • familiarisation visits. You offer to pay for your agent to visit your institution and meet relevant staff face-to-face. This increases your agent’s knowledge of your institution and personalises the professional connection by allowing your admission officers to meet the agents. • additional marketing support. This could be financial or physical support, whether by organising more joint promotions in-country or providing more financial support for marketing activities. You may want to use one or a combination of these incentives to motivate your agent – a combination of financial and non-financial incentives seems to be most effective. The decision of whether to use an incentive scheme or whether you can engage and motivate your agents one-on-one will depend on your resources, size and long-term growth plans. For example, if you have appointed a small number of agents they might be easily managed personally; however, unless you have a dedicated agent manager as you grow and appoint more agents, you might want to consider managing your agents within a management model. Many larger VET providers and universities are now using Incentive Management Models to strategically rank and provide incentives for their top performing agents. Agents are categorised and ranked against selection criteria based on performance and the provider–agent relationship. The selection criteria again should be based on your institutional objectives and should be at a macro level to account for market level diversity. For example, Table 7 illustrates how agents may be ranked into four levels depending on their performance in recruiting and their length of association with the organisation. Agents are recruited as bronze agents and then, through consistently achieving and exceeding their key performance indicators, can be recognised and rewarded for their loyalty and hard work. Table 7: Agent Rankings Rank Description No. of Students Revenue target Bronze New agents < 20 Silver Existing agents demonstrating growth in students > 20 numbers and meeting minimum targets Gold Key agent in targeted markets > 40 Use of sub-agents to recruit large numbers of students Platinum As above plus >50 $ 500,000 Business development activities for industry and institutional partnerships Each level offers incentives and rewards to encourage progression to the next level, as shown in Table 8. 30 International Education Agent Management | A Best Practice Guide
  • 33. Table 8: Agent Incentives and Rewards Relationship Structure Bronze Silver Gold Platinum Length of Agreement 1 year 2 years 3 years 3 years Performance Review 6 1 year 1 year 1 year months Monthly report   Incentive / Benefits Commission rate - ELICOS 20% 20% 20%+3% 20%+ 4% over over target target revenue revenue Commission rate - Diploma 15% 15% 15% 15% Commission rate – Other (Study tours, etc) - - 10% 10% Commission rate based on revenue - - - 1.5% revenue generated Familiarisation visit – assistance arranging visits     Partner Certificate     Regular newsletter     Listing on web site     Training support – web based     Scholarships scheme    Familiarisation visit - paid visit to Queensland   Promotional Budget - $2000   Agreement administrative / marketing expenses paid   Training support (in person)   Signage on site  International Education Agent Management | A Best Practice Guide 31
  • 34. 3.3. Contracting Agents POLICY: The National Code (2007) Standard 4.1 states: The registered provider must enter into a written agreement with each education agent it engages to formally represent it. The agreement must specify responsibilities of the education agent and the registered provider and the need to comply with the requirements of the National Code. The agreement must include: • processes for monitoring the activities of the education agent, including where corrective action may be required, and • termination conditions, including provision for termination in the circumstances outlines in Standard 4.4. In addition to compliance with the National Code, the contract provides a document of reference to manage your relationship with the agent and the agent with you. As a minimum the agent contract should include: Service Provisions • roles and responsibilities of each party • a clear indication of the territory or geographical area the agent is responsible for Key Performance Indicators • Key Performance Indicators including student targets, processing times and partner introductions Incentives • incentive schemes • commission structures Basic Contractual Concerns • the duration of contract and termination clauses • provision for the document to fall within Australian legal jurisdiction whenever possible. As with any legal document it is essential this be reviewed by your organisation’s legal representatives. 3.3.1. The Service Provision The roles and responsibilities should be based on your business strategic objectives and priorities. You should keep in mind the reasons you are appointing the agent in that particular market and the services the agent offers and align the service provisions accordingly. If the agent is a new agent you may wish to appoint them to basically serve the market. As the relationship grows you could increase the service provision. You should note that, the higher the level of services you require, the higher your responsibilities towards the agent, such as increases in training, monetary support and time. Clearly Defined Territories It should also be made clear which geographical areas the agent is servicing. This will make it easy for you to manage your agents as well as stay focused on your organisational needs and objectives. There are a number of reasons for this: • Different markets may need different approaches. The agent you have appointed for a particular market may not be suitable to meet your objectives in a different market. • An agent expanding or encroaching into another territory may have implications on your relationship with existing successful agents or partners in that territory. • You may not have the resources to service another market. 32 International Education Agent Management | A Best Practice Guide
  • 35. To clarify this, it should be noted that agents’ territories might be defined but not the nationalities they can recruit. For example, an agent servicing Slovakia would be able to recruit a Korean student if they were recruited within that territory. A Taiwanese agent based in Brisbane might have a defined territory of South East Queensland and Taiwan. The size of the territory would be up to you and the nationalities of those recruited within the territory would not be restricted. 3.3.2. Key Performance Indicators Once the services have been decided and documented, key performance indicators (KPIs) should also be established. KPIs should be established together so the agent has some ownership over them and they are also realistic. There is no point setting a KPI of 50 students when you are a small provider with a population of 100 international students. If the KPIs are unrealistic then the agent will not work productively for you and the partnership will not reach its potential. Examples of KPIs include: • number of student applications sent by agent • conversion percentage of applications to enrolments • length of application processing times • number of partnership introductions made. As mentioned, KPIs will depend on the agent and the market. An agent who primarily provides business development services and recruits students through these opportunities would have different KPIs to an agent who primarily recruits students through a number of promotional and marketing activities such as student recruitment fairs. Ranking and incentives schemes can encourage agents to work above and beyond their KPIs. 3.3.3. Remuneration and Incentives Payment procedures and incentives should be clearly stipulated in the contract and strictly adhered to. If using incentives or an Incentive Management Model, these should be clearly documented either in the body of the contract or in the form of an attached Schedule. 3.3.4. Basic Contractual Concerns As per all legal documents, the following should be included in any agent contract: Length of the agreement Most providers have a basic 12-month validation period from the time the agreement is signed. The length of the contract will depend on a number of factors including: your relationship with the agent; the resources you have to conduct a review and renewal of agreement; and your positioning in the marketplace. If you are using a management model and you have a long and established relationship with your agent, the term may be three years. If it is a new partnership, you might want to have a probationary period of six to twelve months. If you are a small provider you need to consider the resources you have to conduct reviews and renewals of agents. If you have over 50 agents and all agreements expire at the same time it might be a large job to review and renew all of them. If this is the case you may want to consider a management model and ranking your agents. International Education Agent Management | A Best Practice Guide 33