Anti-Bribery & Anti-Corruption Policy

1 Policy Statement

WorldStudentAdvisors prohibits the offering, giving, requesting, or accepting of any bribe, facilitation payment, inducement, or improper advantage of any kind, whether financial or non-financial.

This applies to all business relationships, including interactions with students, universities, agents, partners, suppliers, and government bodies.

2 Scope

This policy applies to:

• The Managing Director
• All employees, consultants, contractors, and volunteers
• Overseas representatives, agents, sub-agents, and referral partners
• Any third party acting on behalf of WorldStudentAdvisors

This policy applies to all activities undertaken by WorldStudentAdvisors in the United Kingdom and internationally.

3 Legal & Regulatory Framework

This policy supports compliance with:

• The UK Bribery Act 2010
• Guidance issued under the UK Bribery Act 2010
• Other applicable UK legislation relating to bribery and corruption
• Relevant legislation in jurisdictions in which WorldStudentAdvisors operates
• Contractual obligations with university partners

This policy is aligned with the National Code of Ethical Practice for UK Education Agents and the British Council Agent Quality Framework (AQF).

4 Definition of Bribery

Bribery is defined as any financial or other advantage offered, promised, given, requested, or received with the intention of inducing or rewarding improper performance. Examples include, but are not limited to:

• Cash payments or cash-equivalent gifts
• Excessive or inappropriate hospitality or entertainment
• Undisclosed or improper commissions or referral fees
• Favours, employment offers, or preferential treatment
• Non-financial inducements intended to influence decisions

5 Prohibited Conduct

WorldStudentAdvisors strictly prohibits:

• Offering or accepting bribes of any kind
• Facilitation payments, including so-called "speed money"
• Kickbacks, undisclosed commissions, or improper incentives
• Gifts or hospitality intended to influence decisions
• Any attempt to improperly influence admissions decisions, visa outcomes, or academic processes

6 Gifts & Hospitality

Gifts and hospitality must be:

• Reasonable and proportionate
• Infrequent and modest in value
• Not intended to influence a business decision
• Transparent and appropriate in the circumstances
• Compliant with university partner policies

Cash or cash-equivalent gifts are not permitted under any circumstances.

7 Third Parties & Representatives

WorldStudentAdvisors undertakes appropriate due diligence on agents, representatives, and partners. All third parties acting on behalf of WorldStudentAdvisors are required to:

• Comply with this policy
• Operate transparently and ethically
• Refrain from offering or accepting bribes or inducements

WorldStudentAdvisors retains responsibility for the conduct of its representatives in accordance with partner agreements. Any breach may result in termination of the relationship.

8 Responsibilities

9 Reporting Concerns

Concerns or suspicions relating to bribery or corruption must be reported promptly and in confidence to:

All reports will be taken seriously, reviewed appropriately, and handled without retaliation.

10 Breaches

Breaches of this policy may result in:

• Disciplinary action
• Termination of employment or contractual arrangements
• Termination of agency or partnership agreements
• Referral to relevant authorities where appropriate

11 Monitoring & Review

This policy is subject to periodic review to ensure continued alignment with applicable legislation, university partner requirements, and sector guidance and best practice.

12 Publication

This policy is published on the WorldStudentAdvisors website and may be provided to university partners, auditors, or regulatory bodies upon request.