Agent Code of Conduct

This Agent Code of Conduct ("Code") is issued by LOPEX UNICONS LTD (trading as UNICONS), 214 High Street, Second Floor, Hounslow, TW3 1HB, London, United Kingdom ("UNICONS"), and applies to all individuals and organisations registered as agents on the UNICONS Platform.

The purpose of this Code is to ensure that every Agent conducts educational recruitment activities to the highest professional and ethical standards, safeguards the welfare and interests of Prospective Students, maintains the integrity and reputation of UNICONS and its Partner Institutions, and complies with all Applicable Laws.

This Code forms part of the Agent Agreement Suite and must be read alongside the Agent Registration Agreement, the Agent Referral Agreement, and the Agent Confidentiality and Data Processing Agreement. By registering as an Agent and ticking the acknowledgement box, you agree to be bound by this Code in all your recruitment activities, whether conducted through the UNICONS Platform or independently in connection with UNICONS-related services.

UNICONS reserves the right to update this Code from time to time and will notify Agents of material changes via the Agent Portal. Continued engagement as a UNICONS Agent after the effective date of any update constitutes acceptance of the revised Code.

2.1 General Conduct. Every Agent must conduct themselves and their staff in a professional, honest, and courteous manner in all dealings with Prospective Students, UNICONS personnel, and Partner Institution representatives. Agents are expected to be knowledgeable about the institutions, programmes, and admissions processes relevant to their work and to take reasonable steps to keep that knowledge current.

2.2 Competence and Continuing Development. Agents shall not advise Prospective Students on matters outside their competence. Where a student raises queries beyond the Agent's knowledge — including questions about specific visa requirements, immigration eligibility, programme accreditation details, or scholarship eligibility — the Agent shall acknowledge the limitation honestly and direct the student to the appropriate authoritative source or qualified professional.

2.3 Conflict of Interest. Agents shall promptly disclose to UNICONS any actual or potential conflict of interest that may affect their ability to act impartially in the interests of Prospective Students. This includes, without limitation, any financial interest in a competing referral network, employment by or ownership interest in a Partner Institution, or any personal relationship with a student that could compromise objectivity.

2.4 Professional Image. When representing themselves as UNICONS agents, individuals and organisations shall conduct themselves in a manner consistent with the values and standards of UNICONS. Agents shall not engage in conduct — online, in person, or otherwise — that is likely to embarrass, harm, or bring into disrepute UNICONS or any Partner Institution.

3.1 Prohibition on False Claims. Agents are strictly prohibited from making any false, misleading, or unsubstantiated claims about UNICONS, its services, the Platform's capabilities, Partner Institutions, course quality, graduate outcomes, employment rates, ranking positions, or any other matter that may influence a Prospective Student's decision.

3.2 Accuracy of Course Information. Agents must provide information about courses, entry requirements, tuition fees, duration, and available scholarships that is accurate and consistent with the current published information of the relevant Partner Institution. Agents must not:

(a) understate or misrepresent entry requirements (including English language requirements, academic qualifications, or work experience requirements);

(b) misrepresent the total cost of study by omitting accommodation, living costs, health surcharges, or other predictable expenses;

(c) overstate or fabricate graduate employment outcomes, salary expectations, or post-study visa eligibility;

(d) imply that a course is easier or faster than its published specification.

3.3 Limitation on Commission Disclosure. Agents must not actively conceal the fact that they earn commission from Partner Institutions for successful referrals. Agents must be willing to confirm this fact honestly if asked by a student. Agents must not represent their services as wholly independent or impartial financial advice.

3.4 Advertising Standards. All advertising and marketing materials produced by the Agent in connection with UNICONS or Partner Institutions must comply with the UK's Advertising Standards Authority (ASA) codes (CAP and BCAP) and any equivalent standards in the jurisdictions in which the Agent operates. Marketing materials must be clearly identified as advertising where required by applicable standards.

3.5 Approval of Co-Branded Materials. Any marketing material that incorporates UNICONS' brand name, logo, or trademarks must be submitted to UNICONS for written approval before publication or distribution. UNICONS reserves the right to withdraw approval for any previously approved material where it becomes inaccurate or inconsistent with UNICONS' brand guidelines.

4.1 Course Fees. Agents must present fee information accurately and in full. It is a serious breach of this Code to:

(a) quote fees that are out of date without disclosing that fees are subject to change and directing the student to verify the current fee schedule with the institution;

(b) fail to distinguish between home and international student fee levels where applicable;

(c) represent that fee waivers or discounts are available without having verified their current availability with the Partner Institution.

4.2 Entry Requirements. Agents must not represent to a student that they meet the entry requirements of a programme if the Agent has reason to believe the student does not meet those requirements. Agents must not advise students to submit applications they know to be inaccurate or misleadingly presented in order to satisfy entry requirement thresholds.

4.3 Visa Conditions. Agents must not advise students on the specific legal requirements for a UK Student Visa (or any other visa) unless the Agent holds appropriate OISC Level 1 authorisation or higher, or is a practising solicitor regulated by the SRA. Agents may provide general factual information about the existence of visa requirements but must refer students to an authorised immigration adviser for specific advice. Agents must not:

(a) promise or imply that a student will obtain a visa if they apply through the Agent or UNICONS;

(b) advise students that they do not require a visa when that advice is not objectively verifiable;

(c) assist students in misrepresenting their circumstances to UKVI.

5.1 Student-Centred Approach. Agents must at all times prioritise the genuine educational interests and welfare of each Prospective Student. Recommendations must be based on the student's actual academic background, career goals, financial circumstances, and personal preferences — not on the commission rate offered by a particular institution.

5.2 Prohibition on Pressure Tactics. Agents must not subject Prospective Students to high-pressure sales tactics, artificial urgency (e.g. false claims of imminent application deadlines or limited places), emotional manipulation, or persistent harassment following an expression of disinterest. Agents must respect a student's decision not to proceed with an application.

5.3 Protection of Vulnerable Individuals. Agents shall take additional care when dealing with individuals who may be in a vulnerable position, including minors, individuals with limited English proficiency, individuals in financial difficulty, or individuals who appear to be under undue influence from family members or third parties. Where an Agent suspects a student is being coerced, exploited, or trafficked, the Agent must report this immediately to UNICONS and, where appropriate, to the relevant authorities.

5.4 Prohibition on Charging Students. Agents must not charge, request, or accept any fee, commission, gift, or financial benefit from any Prospective Student or their family in connection with referral, application, or advisory services provided under or in connection with this Code. All Agent remuneration under the UNICONS network is provided exclusively by UNICONS through the commission structure.

5.5 Informed Decision-Making. Agents must ensure that each student makes their application decision on the basis of full and accurate information, including a clear understanding of: the total costs of study; the commitments required by the course; the realistic prospects of meeting entry requirements; and the student's own rights to withdraw or complain.

6.1 Equal Treatment. Agents must not discriminate against any Prospective Student on the grounds of age, disability, gender reassignment, marriage or civil partnership status, pregnancy or maternity, race (including colour, nationality, and ethnic or national origins), religion or belief, sex, or sexual orientation, in accordance with the Equality Act 2010 and equivalent laws in the Agent's operating jurisdiction.

6.2 Inclusive Practice. Agents shall make reasonable adjustments to their processes and communications to ensure that students with disabilities or additional needs are not placed at a substantial disadvantage in accessing the Agent's services.

6.3 No Discriminatory Recommendations. Agents must not steer students toward or away from particular institutions or programmes on the basis of any protected characteristic. Recommendations must be based solely on the student's academic profile, aspirations, and circumstances.

7.1 Written Communications. All written communications with Prospective Students, UNICONS, and Partner Institutions must be clear, professional, and accurate. Agents must not use misleading subject lines, impersonate UNICONS or Partner Institution staff, or send unsolicited bulk communications (spam) in breach of the Privacy and Electronic Communications Regulations 2003.

7.2 Response Timeliness. Agents shall respond to student enquiries and UNICONS communications in a timely manner consistent with the expectations of a professional service provider.

7.3 Confidentiality in Communications. Agents must not share details of one student's application or personal circumstances with other students or third parties. All student communications must be treated as confidential in accordance with the Agent Confidentiality and Data Processing Agreement.

8.1 Accuracy Online. All content published by the Agent on social media platforms, websites, YouTube, TikTok, Instagram, WhatsApp groups, or any other digital channel that references UNICONS, Partner Institutions, or the Agent's services as a UNICONS affiliate must comply with the accuracy and non-deception requirements of this Code.

8.2 Disclosure of Affiliation. Where an Agent publishes promotional or informational content about institutions available through UNICONS in connection with their referral activities, the Agent must clearly disclose their commercial relationship with UNICONS in accordance with ASA guidance on influencer and affiliate marketing (e.g. by using the hashtag #ad or a clear disclosure statement where required).

8.3 Prohibited Digital Conduct. Agents must not:

(a) make deceptive promises of guaranteed admission, guaranteed visas, or guaranteed scholarships in any digital channel;

(b) solicit student personal data through unofficial channels (e.g. WhatsApp forms or Google Forms) in lieu of the Platform's official registration process, without UNICONS' express written consent;

(c) collect students' passport details, biometric data, or financial account information through any channel other than the Platform or a secure system that meets the data security standards in the Agent Confidentiality and Data Processing Agreement;

(d) run paid advertisements using UNICONS' trade name, logo, or branded keywords without prior written approval from UNICONS.

8.4 Takedown Obligation. Upon expiry or termination of the Agent's registration, the Agent must remove all UNICONS-branded content and any claim to be an authorised UNICONS agent from all digital channels within seven (7) calendar days.

9.1 Suspected Fraud. If an Agent becomes aware or reasonably suspects that any student, colleague, or third party is engaged in fraud in connection with a UNICONS-related application — including but not limited to document fabrication, identity fraud, or visa fraud — the Agent must notify UNICONS immediately and in writing at enquiry@unicons.co.uk. The Agent must not confront the individual suspected of fraud directly in a manner that could compromise any subsequent investigation.

9.2 Student Welfare Concerns. If an Agent has serious concerns about the welfare, safety, or wellbeing of any Prospective Student — including concerns about exploitation, coercion, mental health crisis, or safeguarding — the Agent must contact UNICONS immediately. Where there is an immediate risk to a student's safety, the Agent must contact the relevant emergency services in the applicable jurisdiction without delay.

9.3 Regulatory Notifications. Where an Agent is subject to any regulatory investigation, sanction, or professional disciplinary action that is relevant to its activities as a UNICONS Agent, the Agent must notify UNICONS in writing within five (5) business days of becoming aware of such action.

10.1 Business Confidentiality. Agents must keep confidential all non-public information about UNICONS' commercial operations, commission structures, partner agreements, platform developments, and strategic plans that comes to their knowledge in the course of their engagement as a UNICONS Agent. This obligation shall survive termination of the Agent's registration.

10.2 Student Data. Agents must handle all student personal data in accordance with the Agent Confidentiality and Data Processing Agreement and must not disclose student data to any third party except as required for the legitimate purpose of facilitating the student's application.

10.3 No Public Disparagement. Agents must not publicly disparage, defame, or make misleading negative statements about UNICONS, its staff, its Partner Institutions, or their products or services in any forum, whether online or offline.

11.1 Range of Consequences. Breach of any provision of this Code may result in the following actions by UNICONS, applied proportionately to the nature and severity of the breach:

(a) Written Warning: issued for minor or first-time breaches where the Agent cooperates fully and takes prompt remedial action;

(b) Temporary Suspension: suspension of access to the Agent Portal and withholding of pending commission payments pending investigation, where a potential material breach is under review;

(c) Commission Forfeiture: forfeiture of pending or future commission payments attributable to referrals generated during the period of non-compliance;

(d) Termination: permanent termination of the Agent's registration and all associated agreements, without right to compensation, in cases of serious or repeated breach;

(e) Reporting to Authorities: referral of the matter to relevant regulatory bodies, law enforcement agencies, or the relevant national educational regulation authority where the breach involves fraud, immigration misconduct, bribery, or child protection issues.

11.2 Right to Appeal. An Agent subject to suspension, commission forfeiture, or termination under this clause may submit a written appeal to UNICONS within fourteen (14) calendar days of receiving notice of the action. UNICONS shall consider the appeal and provide a written response within twenty (20) business days. Appeals do not suspend the enforcement of any measure pending the outcome unless UNICONS expressly agrees otherwise.

11.3 No Waiver. UNICONS' failure to enforce any provision of this Code on any occasion shall not constitute a waiver of its right to enforce that provision on any future occasion.

11.4 Governing Law. This Code and any dispute arising out of or in connection with it shall be governed by and construed in accordance with the law of England and Wales, and the parties submit to the exclusive jurisdiction of the courts of England and Wales.