Counsellor Code of Ethics

This Counsellor Code of Ethics ("Code") sets out the ethical principles, values, and professional standards that every Counsellor engaged by LOPEX UNICONS LTD (trading as UNICONS) must uphold in all aspects of their work with students, institutional partners, colleagues, and other stakeholders.

UNICONS' mission is to connect students with genuine educational opportunities that are right for them. That mission can only be fulfilled when students trust that the advice they receive is honest, independent, and given in their best interests. This Code is accordingly not aspirational guidance — it is a binding set of obligations, acceptance of which is a condition of engagement as a Counsellor. Breach of any provision of this Code may result in disciplinary action up to and including immediate termination of engagement and, where applicable, referral to professional or regulatory bodies.

This Code applies to all Counsellors irrespective of their employment status (employed or contracted), the student's country of origin, the institution being considered, or the commercial relationships that UNICONS holds with any institution. It applies to all communications with students and other parties whether conducted via the UNICONS platform, by telephone, in person, or by any other means.

Every Counsellor is required to internalise and consistently demonstrate the following core ethical principles:

2.1 Honesty The Counsellor shall be truthful in all communications with students and stakeholders. This means: presenting information accurately and without embellishment; not withholding material information that a student needs to make an informed decision; not misrepresenting the Counsellor's own qualifications, experience, or authorisations; and correcting any previous error or misstatement promptly upon discovery.

2.2 Integrity The Counsellor shall act with integrity at all times, meaning that their professional conduct must be consistent with the values and obligations in this Code regardless of who is observing, the commercial stakes involved, or the preferences of any third party. Integrity requires the Counsellor to refuse instructions that would require them to act unethically, and to raise concerns openly rather than suppress them.

2.3 Student Welfare The welfare of the student — including their academic, financial, psychological, and personal wellbeing — is the paramount consideration in every interaction. Where a Counsellor identifies that a proposed course of action (whether suggested by the student, a third party, or arising from commercial pressure) may be harmful to the student's welfare, the Counsellor must raise this concern clearly and, where necessary, take protective action in accordance with UNICONS' safeguarding and reporting procedures.

2.4 Impartiality The Counsellor shall give advice and make recommendations without partiality, prejudice, or external commercial influence. Impartiality requires the Counsellor to evaluate all suitable options for a student fairly, without giving undue weight to institutions with which UNICONS has a preferred commercial relationship, and without being influenced by personal preferences or prior relationships with institutional contacts.

2.5 Professional Competence The Counsellor shall operate only within the scope of their knowledge, skills, and authorisations. Where the Counsellor lacks the competence or authorisation to address a particular matter (including regulated immigration advice), they must acknowledge this limitation clearly to the student and make an appropriate referral without delay.

3.1 Student-Profile-Driven Advice All recommendations as to universities, colleges, courses, countries, entry pathways, and related matters must be grounded in a genuine assessment of the individual student's academic profile, qualifications, language proficiency, financial capacity, career aspirations, personal preferences, and any relevant personal circumstances. The Counsellor must be able to articulate a clear, evidence-based rationale for every recommendation made.

3.2 Prohibition on Commission-Driven Recommendations The Counsellor is expressly prohibited from allowing commission rates, recruitment targets, bonus structures, or any other financial incentive to influence the recommendations made to a student. Where UNICONS has a commercial arrangement with an institution that includes a commission or referral fee, the Counsellor must be able to demonstrate that any recommendation of that institution is based solely on its suitability for the student. Failure to maintain this separation constitutes a serious breach of this Code.

3.3 Transparency About Commercial Relationships Where a student asks whether UNICONS receives a fee or commission from an institution that has been recommended, the Counsellor must confirm that commercial arrangements may exist and direct the student to UNICONS' published disclosure information. The Counsellor must not be evasive or misleading in response to such enquiries.

3.4 Presentation of Multiple Options Where multiple suitable options exist for a student, the Counsellor should present a balanced range of options rather than steering the student towards a single institution. The Counsellor must respect the student's right to make an informed, autonomous choice and must not use pressure, urgency framing, or selective presentation of information to manipulate the student's decision.

3.5 Honesty About Likelihood of Success The Counsellor must provide a frank and honest assessment of the student's prospects at each institution being considered, including where those prospects are limited. The Counsellor must not inflate a student's perceived chances of success in order to obtain consent to submit an application, collect a fee, or achieve a conversion target.

4.1 No Misrepresentation The Counsellor must not make any statement to a student or to an institution that the Counsellor knows, or ought reasonably to know, to be false, misleading, or likely to create a false impression. This prohibition applies to: descriptions of courses, institutions, or entry requirements; representations about the student's qualifications or profile; statements about UNICONS' services, accreditations, or relationships; and claims about outcomes achieved for previous students.

4.2 No Selective Disclosure Providing technically accurate information in a manner that is misleading by omission is as much a breach of this Code as an outright falsehood. The Counsellor must not deliberately omit material information — including negative information about an institution's reputation, ranking, graduate employment outcomes, or regulatory standing — where that information would be relevant to the student's decision-making.

4.3 Distinguishing Opinion from Fact The Counsellor must clearly distinguish between factual information (which must be accurate) and their own professional opinion or assessment (which must be genuinely held and disclosed as such). The Counsellor must not present a professional opinion as a confirmed fact or vice versa.

4.4 No False Urgency or Pressure Tactics The Counsellor must not use false claims of limited availability, manufactured urgency, or psychological pressure tactics to influence a student's decision. All deadlines communicated to students must be genuine, verifiable, and accurately represented.

5.1 No Guarantee of Admission The Counsellor must not guarantee, promise, or imply a guarantee of admission to any university, college, or educational institution. Admission decisions are made independently by institutions and are subject to their own academic, commercial, and regulatory considerations. No Counsellor — regardless of their experience or relationship with an institution — can guarantee an outcome.

5.2 No Guarantee of Visa Success The Counsellor must not guarantee, promise, or imply that a student will be granted a visa or entry clearance. Visa decisions are made by the Home Office and, for international pathways, by the immigration authorities of the relevant country. The Counsellor must make this limitation clear to students from the outset of any visa-related discussion.

5.3 No Guarantee of Scholarships or Financial Awards The Counsellor must not represent to a student that they will or are likely to receive any scholarship, bursary, tuition waiver, or other financial award unless the Counsellor has specific, verifiable evidence that this is the case. Even where a student appears highly eligible, the Counsellor must make clear that awards are competitive and that the outcome cannot be assured.

5.4 Permitted Expressions of Optimism The prohibition on guaranteeing outcomes does not prevent a Counsellor from expressing a professional opinion that a student's application is strong, that their profile is competitive, or that their prospects are good — provided that such views are genuine, based on the available evidence, and clearly expressed as opinion rather than certainty.

6.1 Acknowledgement of Knowledge Limits The Counsellor must not advise a student on matters outside the Counsellor's knowledge or competence. Where the Counsellor is uncertain about a fact — including current entry requirements, scholarship conditions, or visa rules — they must acknowledge this uncertainty to the student, conduct appropriate verification, and not proceed on the basis of potentially incorrect information.

6.2 Referral for Regulated Activities Where a student requires regulated immigration advice, the Counsellor must refer them without delay to an OISC-registered adviser or a solicitor regulated by the Solicitors Regulation Authority (SRA). Referrals must be documented within the UNICONS platform. The Counsellor must not attempt to provide regulated immigration advice as a workaround, nor must they advise a student to disregard the need for regulated advice.

6.3 Referral for Personal Support Where a student discloses personal circumstances that suggest a need for mental health support, financial counselling, legal advice, or other professional assistance, the Counsellor should acknowledge the student's disclosure sensitively and, where appropriate, signpost available support resources. The Counsellor must not attempt to provide professional advice outside their competence and must follow UNICONS' welfare referral procedures.

A Counsellor who advises on the basis of outdated information risks causing serious harm to students. Accordingly, the Counsellor has an ongoing professional duty to maintain current, accurate knowledge in the following areas:

7.1 University Entry Requirements The Counsellor must ensure that their knowledge of entry requirements — including academic qualification equivalences, English language requirements, portfolio requirements, and admissions test requirements — for the institutions and programmes on which they advise is up to date. Entry requirements change regularly; the Counsellor must verify requirements from institutional sources before advising and must not rely solely on historical knowledge or general assumptions.

7.2 Visa and Immigration Rules The Counsellor must maintain awareness of the general requirements, categories, and processes applicable to UK Student visas and other relevant immigration pathways. Where rules change — as they frequently do — the Counsellor must update their general knowledge promptly. The Counsellor must always direct students requiring specific visa advice to a regulated adviser.

7.3 Scholarship and Funding Availability The Counsellor must keep their knowledge of major scholarship programmes, funding bodies, and financial aid options reasonably current. Where a student is seeking funding, the Counsellor must verify the availability and current eligibility criteria of any scholarship before recommending the student apply.

7.4 Mandatory Training The Counsellor must complete all mandatory and refresher training prescribed by UNICONS, including training on updates to platform systems, changes in institutional partner requirements, and relevant regulatory developments. Failure to keep knowledge current may itself constitute a breach of this Code.

8.1 General Prohibition on Exploitation The Counsellor must not exploit any student — financially, emotionally, sexually, or in any other manner. This prohibition applies to all students and is of heightened importance in relation to vulnerable students, as defined below.

8.2 Vulnerable Students The Counsellor must be particularly alert to the needs and vulnerabilities of students who are:

• Minors (under 18 years of age): The Counsellor must comply with UNICONS' Child Safeguarding Policy, ensure that all communications with minors are conducted with appropriate oversight, and must never engage in one-to-one communications with a minor outside the UNICONS platform without a parent or guardian's knowledge;
• In Financial Difficulty: The Counsellor must not recommend unnecessary services, premium packages, or additional applications to students who are in evident financial difficulty, and must not use a student's financial vulnerability as leverage;
• Fleeing Conflict or in Crisis Situations: The Counsellor must treat students who are displaced, seeking asylum, or in crisis with exceptional sensitivity, must not exploit their urgency or desperation, and must ensure that all advice given is accurate, realistic, and genuinely in the student's interests.

8.3 Prohibition on Personal Financial Relationships The Counsellor must not enter into any personal financial arrangement with a student, including but not limited to: lending money; borrowing money; receiving payment from a student for services other than through UNICONS' authorised payment processes; recommending a student to any third-party service in which the Counsellor has a financial interest without full prior disclosure and UNICONS' written consent.

8.4 Professional Boundaries The Counsellor must maintain appropriate professional boundaries with all students. Personal or romantic relationships with current students are prohibited. Where a personal relationship with a former student is or becomes relevant to the Counsellor's professional duties, the Counsellor must disclose this to UNICONS immediately.

8.5 Gifts and Hospitality The Counsellor must not solicit or accept gifts, hospitality, or other benefits from students or their families that could be seen to create an obligation or conflict of interest. Where a student or family member insists on offering a token of appreciation, the Counsellor must comply with UNICONS' Gifts and Hospitality Policy and declare any such receipt.

9.1 Safeguarding Concerns Where the Counsellor becomes aware of or reasonably suspects that a student is at risk of harm — including harm arising from abuse, exploitation, trafficking, coercion, or mental health crisis — the Counsellor must report this concern to UNICONS' designated safeguarding lead without delay. Where a student is a minor and there is immediate risk of harm, the Counsellor must also consider whether a report to statutory authorities (such as children's social care or the police) is required. Counsellors must not delay reporting on the grounds that they wish to investigate further themselves.

9.2 Suspected Fraud The Counsellor must report immediately to UNICONS any suspicion or evidence of fraud, including but not limited to: falsified academic documents; fabricated financial evidence; plagiarised or purchased application materials; misrepresentation of identity; or corrupt practices involving any party in the application process. The duty to report applies regardless of whether the fraud is perpetrated by the student, a third party, an institutional contact, or another Counsellor.

9.3 Concerns About Other Counsellors or Staff The Counsellor has a duty to report concerns about the conduct of other Counsellors or UNICONS staff where such conduct appears to breach this Code, the Counsellor Terms of Engagement, the Counsellor Confidentiality Agreement, or applicable law. Reports may be made to the relevant line manager or, where the concern involves management, via UNICONS' confidential whistleblowing channel. UNICONS is committed to protecting Counsellors who make good-faith reports from any form of retaliation.

10.1 Disciplinary Action Any breach of this Code will be taken seriously and will be investigated by UNICONS. Depending on the severity and circumstances of the breach, disciplinary action may include: a formal written warning; mandatory additional training; increased supervision; suspension of platform access pending investigation; termination of engagement (with or without notice, depending on the seriousness of the breach).

10.2 Referral to Regulatory Bodies Where a breach of this Code involves conduct that may engage the jurisdiction of a regulatory or professional body — including the Information Commissioner's Office, the OISC, the police, or any relevant professional membership organisation — UNICONS reserves the right to refer the matter to the appropriate authority.

10.3 Civil and Criminal Liability The Counsellor acknowledges that certain breaches of this Code may also give rise to civil or criminal liability independently of their engagement with UNICONS. This includes, without limitation, provision of regulated immigration advice without authorisation (a criminal offence under the Immigration and Asylum Act 1999), failure to report safeguarding concerns in circumstances where a legal duty exists, and fraudulent misrepresentation.

10.4 No Waiver UNICONS' failure to act on a breach immediately shall not constitute a waiver of the right to take action in respect of that breach or any subsequent breach. All obligations under this Code remain in force throughout the Counsellor's engagement and, where applicable, following termination.

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*Questions about this Code should be directed to UNICONS at enquiry@unicons.co.uk or by writing to 214 High Street, Second Floor, Hounslow, TW3 1HB, London, United Kingdom.*