FOI_25-141 Agent Quality Framework Pledge
Date of response: 03 June 2025
We have now considered your request of 07 May 2025 for the following information:
Your university has signed the Agent Quality Framework (AQF) pledge as part of its use of agents to recruit international students to the university. I am writing with a freedom of information request about your signing of this. I'm looking for clarity on your understanding, implementation and compliance of it.
1.1Do you believe you have fully implemented all elements of the AQF?
Our response:
No, not as of the date of your request. Whilst the University of East Anglia (UEA) has implemented some of the elements, the University is still in the process of implementing some key elements of the AQF.
1.2 - If not, what date did you sign the pledge, and by what date do you plan to have it fully implemented?
Our response:
UEA signed the pledge in December 2023.
On this occasion it is not possible to provide all of the requested information. In line with your rights under section 1(1)(a) of the Act to be informed whether information is held, we confirm that the University does not hold any recorded information for a date by which we plan to have the pledge fully implemented. The University does not have a planned date for full implementation.
1 .3 If not, what steps are being taken to become fully compliant, if any?
Our response:
We are currently completing a review of the AQF requirements against our current agent management process to highlight areas for development and a plan for implementation. We are participating in an internal audit to support this process.
The below bullet points are some actionable elements of the pledge the University has signed. For each element , please address the questions that follow it. If there are any specific points you can't answer, please explain why but still address any other points that can be answered. I understand some information about University agents may be commercially sensitive, but I am mostly looking for if the university is following the pledge, has the required data, has completed due diligence to follow the pledge, and what this diligence consists of. I dont require the commercially sensitive data, only an understanding of the universities being able to follow the pledge they have signed and if the university has an audit trail even if they don't publicly release it.
• Proactively promote the Student Guide to Choosing an Education Agent to our prospective international students, both directly and through our networks, to aid them in selecting a reliable agent.
2.1- Do you believe the university has fulfilled this element of the pledge?
Our response:
Yes.
2.2- Can you give multiple examples of communication prior to than date of this FOI of where this has been achieved? This is ideally in the public domain, such as social media.
Our response:
Since 2023, recruitment staff have been promoting this element of the AQF to agents and students through in-person discussion. We published links to the British Council’s Student Guide to Choosing an Educational Agent via our website on 17th January 2025, shortly after website domain transition: https://www.uea.ac.uk/study/international-students/agents-we-work-with
• Clearly signpost to our international students the process for registering complaints around their chosen agent.
• Provide students with a clear channel for lodging a complaint if they are dissatisfied with their experience of using a specific education agent.
3.1 Do you believe the university has fulfilled this element of the pledge?
Our response:
Yes.
3.2 Can you show both where students can register complaints on your website and examples of signposting to it.
Our response:
Information pertaining to UEA’s agent network can be found on our website: Agents We Work With - International Students
This page includes a prompt for applicants/students to contact agents@uea.ac.uk should they be looking for an agent to work with in their country or if they are unhappy with an aspect of their applicant experience.
This is in addition to UEA’s Admissions Complaints Procedure - https://www.uea.ac.uk/apply/our-admissions-policy .Students also contact agents@uea.ac.uk to request changes to the agent linked to their current application, these requests are either received directly or via our Admissions/Contacts teams.
If a student is changing agent and hasn’t specified a reason for doing so, and both agents are contracted to UEA, the UEA Global team will proactively follow up with the student to ensure that they have not chosen to change agent due to a negative experience.
3.3 As of the date of this FOI, how many complaints have been registered about agents since the signing of the AQF?
Our response:
Zero. We have not received any complaints following signing of the AQF pledge.
• Clearly display our list of contracted agents on our website to aid international students and their parents or guardians in their choice.
4.1 Do you believe the university has fulfilled this element of the pledge?
Our response:
Yes
4.2 Can you link to where this pledge is met on your website
Our response:
4.3 how many agents does the university work with?
Our response:
199.
• Disseminate the Student Guide to Choosing an Education Agent through relevant communication channels to prospective students.
5.1 Do you believe the university has fulfilled this element of the pledge?
Our response:
Yes.
5.2 Can you give multiple example of it being carried out (ie social media content, email communications, etc) ideally with dates and examples
Our response:
Current example of the information being disseminated is through having the guide hosted on our webpage Agents We Work With - International Students
Planned content for January and September 25/26 cycle:
- Instagram video of a student applying to UEA detailing how they can find out about how to select an agent using our webpages and accessing the BC Student Guide to Choosing an Education Agent
- Webinars open to applicants will show students how they can select an agent using the guide and our UEA website.
- The guide will be linked in the enquirer CRM journey.
• Actively encourage contracted agents to host the Student Guide to Choosing an Education Agent on their website/s and to agree, where feasible, to send a copy to all students who engage their services.
6.1 Do you believe the university has fulfilled this element of the pledge?
Our response:
Not as of the date of your request.
6.2 How has this expectation been communicated to agents?
Our response:
Contractual agreements, CRM and face to face.
We recommend our agents to be signed up for the National Code of Ethical Practise both within our contractual agreement and through emails. The Code of Practice advocates that they complete the British Council training and by proxy publish the student guide on their website.
We also proactively promote the student guide as a good practice tool in our direct communication to agents.
6.3 Are any checks made to see if Education agents do this? If yes, how so?
Our response:
Not as of the date of your request. Checks will be implemented in the forthcoming year, at the point of re-contracting agents.
6.4 Can you provide examples of Education agents the University use meeting this requirement.
Our response:
Not applicable.
6.5 what is the university's expectation of the phrase 'activity encourage' and 'where feasible'
Our response:
Our interpretation to date has been to impress upon agents the importance of providing a transparent and quality service to students, this being something we have always looked for in our partnerships. We have thus followed the tone of current AQF guidance. We will be monitoring this for any changes going forward given the recent adoption of the AQF by Government.
6.6 would the university terminate agents for not hosting or sharing this document?
Our response:
This is not currently one of our termination clauses.
• Regularly monitor and update the details of your contracted agents as listed on your website.
7.1 Do you believe the university has fulfilled this element of the pledge?
Our response:
Yes.
7.2 How often are these checked and reviewed?
Our response:
Monthly (last updated mid-April).
7.3 does the university list all address of all agents offices?
Our response:
All website addresses are listed in our agents list on the website: uea-agents-2025.pdf
• Build The National Code of Ethical Practice for UK Education Agents into our Agent Contracts to highlight their commitment to a quality experience for the student.
8.1 Do you believe the university has fulfilled this element of the pledge?
Our response:
Yes.
8.2 Are there any mandatory requirements for agents to meet this point in your contracts? If yes, how are agents meeting this point audited to ensure compliance?
Our response:
No. There are currently no mandatory clauses, just advisory.
• Embed governance processes throughout our agent contractual cycle to deliver the highest quality service, including during selection, due diligence, contracting, training, planning and ongoing reviews and contract renewals.
9.1 Do you believe the university has fulfilled this element of the pledge? If yes, how so?
Our response:
Yes. We have always monitored an agency's ability to deliver on this both through due diligence at the point of contract and throughout our relationship (face to face visits, email correspondence and checks before re-contracting).
• Include specific clauses in your education agent contracts that require appointed agents to endorse the National Code of Ethical Practice.
10.1 Do you believe the university has fulfilled this element of the pledge?
Our response:
Yes.
10.2 Are checks made to ensure that all agent partners are following this element?
Our response:
Not as of the date of your request, however this will be introduced this year.
10.3 Can you give examples of education agents the University has partnered with meeting this requirement.
Our response:
Not applicable.
10.4 What is the process regarding agents who have not met this requirement?
Our response:
Not applicable.
• Promote the adoption of the principles and standards set out in the National Code of Ethical Practice and Good Practice Guide for UK Education Agents Partnering for Quality right across our agent network.
11.1 Do you believe the university has fulfilled this element of the pledge?
Our response:
Yes
11.2 If yes, please give examples of how so.
Our response:
It is within our agent contract.
• Build the requirement for contracted agents to undergo an appropriate UK Credited training programme such as the British Council UK Agent and Counsellor Certified Training, so that they are well equipped to give students up-to-date information about studying in the UK.
12.1 Do you believe the university has fulfilled this element of the pledge?
Our response:
Yes.
12.2 Are checks made to ensure that all agent partners are following this element?
Our response:
Yes. Quarterly checks are made to ensure all agent partners follow this element. Checks are also conducted for new agent partners at the point of their signing with UEA.
• Evaluate your agents’ compliance with the National Code of Ethical Practice by including an audit of National Code standards in your [annual] review processes.
13.1 Do you believe the university has fulfilled this element of the pledge? If yes, please give examples of how so.
Our response:
Not at of the date of your request.
• Agree a minimum level of engagement for all agent personnel, who provide advice and assistance to prospective students, to study and complete an appropriate UK Credited training programme.
14.1Do you believe the university has fulfilled this element of the pledge?
Our response:
As above (question 2.2), we introduced the principles of the AQF in our training to agents and through other means.
14.2 Does the university monitor personnel at Education agents? If yes, how so?
Our response:
No.
14.3 Is the university aware of the number of agent personnel in their agent network?
Our response:
No.
14.4 What are minimum engagement levels for agent personnel?
Our response:
To attend a training with a UEA staff member at least once per annum. This is normally done in person but can be virtual.
14.5 How is this audited to ensure agent compliance?
Our response:
The completion of activity reports by International Officers at completion of an agent training session.
14.6 What percentage of agent personnel the University work with have passed British Council training? How is this measured, audited and updated?
Our response:
76.4% of agencies (February 2025)
Measured: Manually processing each agent via the British Council website.
Updated: Quarterly
• Promote the principles of the framework in all your agent and student recruitment and engagement work.
15.1 Do you believe the university has fulfilled this element of the pledge?
Our response:
Yes. We also continue to enhance the content and frequency of our communications.
15.2 If yes, please give examples of activity taken to promote it.
Our response:
We have so far embedded the principles of the AQF in all agent training documentation and in agent CRM with plans to introduce through social media posts over the next cycle.
• Ensure clarity for students regarding the commercial relationships education providers have with education agents.
16.1 Do you clearly inform your students that agents receive a commission for working with them?
Our response:
Yes.
16.2 Do you require agents disclose to students any payment or incentives they receive? If yes, how is this audited?
Our response:
No.
16.3 Do scholarships impact commission that agents can earn, and if so, how do you ensure that students understand that their agent may be financially negatively impacted by a student receiving scholarship.
Our response:
No. Scholarships do not impact on commission levels.
Pledges related to subagents:
• Work with our contracted agents to ensure transparency around the use of sub-agents, clarifying their commitment and processes for ensuring quality throughout their sub-agents network.
• Request transparency around the use of sub-agents. Be clear that an agent’s endorsement of the National Code of Ethical Practice and engagement with an appropriate UK Credited training programme also applies to any sub-agent partners working with the contracted agent.
• Request clarity on the processes for training, managing and quality assuring sub-agents.
• Be clear that the completion of an appropriate UK Certified training programme is applicable for all student-facing staff within sub-agents.
17.1 Do you believe the university has fulfilled all the elements of the pledge related to sub-agent use?
Our response:
We require that our agents appropriately train and monitor any sub agents that they work with as per a clause in our agent contract.
17.2 What percentage of your agents use sub-agents?
Our response:
On this occasion it is not possible to provide any of the requested information. In line with your rights under section 1(1)(a) of the Act to be informed whether information is held, we confirm that the University does not hold any recorded information for the percentage of our agents which use sub-agents. The University do not collect this information from our agents.
17.3 Do you require the same level of details of sub-agents as agents with contracts? If yes, what steps are taken to ensure that sub-agents are held to the same standards as contracted agents?
Our response:
No. This is the responsibility of our contracted agents.
17.4 Does the university train or have contact with sub-agents?
Our response:
No. This is the responsibility of our contracted agents.
17.5 Does the university have data on all sub-agents each agent uses?
Our response:
No. This is the responsibility of our contracted agents.
17.6 How do you monitor sub agents of subagents? Do you believe you know data on all agents that can sell your university?
Our response:
The University does not monitor sub agents of subagents. This is the responsibility of our contracted agents.
No. We do not believe to know all data on all agents which can ‘sell’ our university. The University does not have complete data on all subagents used by our agents.
17.7 Do you use aggregators in your student recruitment?
Our response:
This information is available on our website - Agents We Work With - International Students
17.8 Do you use any of the following aggregators (according to another pledge, you must provide a list of all agents you work with, so this is not confidential information).
LCI (15,000)
Leverage EDU (10,000)
Applyboard (6500)
Adventus.io (8000)
Crizac (5300)
MSN Unify (5000)
Edvoy (5000)
KC (3500)
Educo (3000)
Our response:
This information is available on our website - Agents We Work With - International Students
17.8 Do you have all the details on the subagents which make up the aggregators subagent network? (The number in brackets is the number of subagents the aggregator has declared they have in their subagent network, so you should have the data on 15,000 sub agents listed for LCI for example)
Our response:
No. This is the responsibility of our contracted agents.
17.9. These sub agents can recruit students to the University, what percent of them have been trained by the University?
Our response:
None. This is the responsibility of our contracted agents.
17.10 Do you have accurate comprehensive information on all student facing personnel working within these subagents?
Our response:
No. This is the responsibility of our contracted agents.
17.11 Do you know what percent of personnel working within these subagents have completed British Council training?
Our response:
No. This is the responsibility of our contracted agents.
17.12 What does the university do to audit these aggregators and their compliance to the above be points?
Our response:
The requirement to manage subagents appropriately with regards to training and monitoring is within our contract with the aggregator. We respond to any complaints we receive from students or other sources and take appropriate action.
18.1 Does the university work with any of the following: Independent pathway providers, franchised courses providers, validated courses, other education providers who deliver educational courses in partnership or with permission from with the university, either in the UK or abroad.
Our response:
Yes.
If yes, do the external providers who run these courses recruit in compliance with the AQF? If yes, please answer all the above questions regarding AQF compliance with their answers regarding recruitment for courses they directly recruit for that are connected to the university.
Our response:
Yes. UEA’s key pathway provider signed up to the AQF in early 2024.