International Student Recruitment Agency Management Policy

To provide direction on the appointment, certification, management and termination of external third-party agencies who recruit students on behalf of Seneca.

This policy applies to all external third-party agencies who recruit students on behalf of Seneca and Seneca employees (permanent and contract) who interact with these agencies.

The contract between Seneca and an international student recruitment agency that outlines the terms and conditions under which the services of the agency are provided.

Seneca’s principles and standards that all agencies accept and observe when acting on behalf of Seneca.

Monday to Friday, excluding Saturdays, Sundays, statutory holidays or any other day Seneca has publicly acknowledged that it is closed.

The proof that an agency is certified as a Seneca partner based on their compliance with the standards, responsibilities and practices set forth in Seneca’s policies, the ACC and agency agreement.

A commercial, external third-party that is authorized to recruit students for Seneca through a formal agency agreement. The agency is paid a commission for each successful student enrolment. Agencies can be self-incorporated individuals, privately-owned partnerships, publicly traded corporations or agent aggregators. Agencies can also include education portals, professional associations, education institutions or other entities that are monetarily compensated for their recruitment of students on behalf of Seneca.

Seneca’s online application portal through which contracted agencies can submit student applications.

A PEP is an individual with a high-profile political role and/or who has been entrusted with a prominent public function. Family members and close associates of a PEP are also considered PEPs themselves.

1. Seneca is responsible for the appointment, certification, training, management and termination of agencies.
2. Specific responsibilities include:
   • having contractual oversight of agencies, including their selection, renewal and termination
   • managing agency compliance with all relevant Seneca policies, particularly those related to agency training, support and performance review
   • training agencies during their onboarding and throughout the term of their engagement
   • managing and mitigating reputational and other risks associated with agencies
   • collaborating with stakeholders on agency and relationship management.
3. Seneca-certified agencies are responsible for acting professionally and ethically in accordance with this policy, the Agency Code of Conduct (ACC), the conditions of the agency agreement and other Seneca policies as listed under the Related Seneca policies section.
   

1. Seneca conducts and documents due diligence when assessing the suitability of prospective agencies against appropriate criteria that includes the agency’s:
   • student recruitment experience and application success rates
   • business location and online presence
   • business conduct, annual plans and marketing samples
   • knowledge of Seneca and the Canadian postsecondary education system
   • demonstrated ability to comply with the ACC
   • adherence to anti-money laundering regulations
   • clearance from international sanctions
   • referee feedback.
2. Seneca will collect and record sufficient information to screen the agency, contact person(s) and any beneficial owners against Canadian and international sanctions, PEP and adverse media lists.
3. Seneca will sign an agency agreement with agencies that meet the criteria listed in section 3.1 and demonstrate a commitment to comply with the ACC.
4. Seneca will certify that agencies have fulfilled all the conditions in the agency agreement and have received onboarding training.
5. Only certified agencies can recruit students on Seneca’s behalf.
   
6. Seneca will document and maintain records of agency agreements, due diligence undertaken and certification.
7. A provisional agency agreement may be issued under exceptional circumstances, such as when conditions dictate an accelerated response.

1. Seneca will conduct initial training session(s) for all newly appointed agencies.
2. Seneca will maintain regular contact with agencies and advise them via telephone, written communication, virtual meetings and/or in-person visits to provide updates to training or to refresh marketing materials. Advisement includes details on:
   • updated academic program, school and admission information
   • revisions to procedures and application processes, including the use of IWA
   • information regarding relevant policies and/or changes to legal or regulatory conditions
   • branding guidelines, including the use and placement of Seneca wordmarks, logos and promotional materials.
3. Agencies are expected to undertake at least one training session each year with Seneca, to be delivered during visits or online forums.
4. Agencies are responsible for familiarizing themselves with academic program changes, policies, admissions, marketing materials, application processes, visa regulations and other applicable information.

1. Seneca will monitor contracted agencies’ websites and other media (e.g., social) on a regular basis to ensure accurate and current representation of Seneca-related information, including adherence to the terms and conditions for applications and admission.
2. Seneca may randomly inspect agencies virtually or during on-site visits across any of the elements listed in section 7.2.
3. Agencies who are misrepresenting Seneca are subject to the corrective action outlined in section 8.
4. Seneca will collect information and maintain records of the outcomes of all agency monitoring and inspection activities whenever possible.
5. Seneca will investigate any complaints about an agency that are raised by another agency, student or industry stakeholder.
6. When Seneca finds complaints against an agency are warranted, the agency will be subject to the corrective action outlined in section 8.
7. Seneca may conduct an audit of an agency’s compliance with the agency agreement, the ACC and this policy at any time.

1. Commission payments and any other funds or remittances payable to agencies can only be transferred to agencies in line with the conditions outlined in Seneca’s Anti-Money Laundering and Sanctions (AMLS) policy and procedures.
2. Seneca reserves the right to withhold payments to agencies who are in violation of section 6.1 of this policy and/or the conditions outlined in the agency agreement.
3. Seneca employees must alert Seneca International and the Seneca Compliance Office of any requests that could violate Seneca’s AMLS policy and procedures.

1. Seneca will carry out a formal evaluation of agencies annually and more frequently, where warranted.
2. Seneca will collect the information required to conduct qualitative and quantitative reviews of agency performance. This can include, but is not limited to, enrolment reports, interviews with agencies and their employees, observations of events and interactions with students, prospective students and feedback from internal and external stakeholders.  
3. Seneca will perform sanctions screening prior to the renewal of the agency agreement.
4. Based on the results of the annual review, ongoing monitoring, sanctions screening and other factors, Seneca may or may not re-certify an agency and/or invite an agency to renew their agency agreement at the end of the current agreement term.

1. Seneca will issue a written warning to agencies who are in breach of this policy, their agency agreement or the ACC. The warning will detail the infraction, corrective action and timeframe to complete the corrective action.
2. Agencies are required to submit a written response either acknowledging or appealing the warning within ten (10) business days of the warning issuance date. Should the agency not respond to Seneca’s warning within this time frame, Seneca shall move forward with the corrective action outlined in section 8.5.
3. Seneca will review and provide a written response to agency appeals within fifteen (15) business days of receipt of the appeal.
4. Unless an alternate timeframe is mutually agreed upon by the agency and Seneca, agencies with failed appeals are given ten (10) business days from the time Seneca communicates their decision to remedy the infraction.
5. Agencies identified with unremedied infractions may be subject to some or all of the following actions:
   • additional training as mandated by Seneca
   • restriction of recruitment activities on behalf of Seneca
   • lowering of application and/or commissionable-student quotas, as applicable
   • temporary suspension of the agency’s representation of Seneca.
6. If the agency does not undertake subsequent corrective action(s) after the issuance of the written warning, Seneca reserves the right to terminate the agency agreement in accordance with section 9.
   

1. Seneca may terminate the agency agreement without liability, cost or penalty at any time, in accordance with the conditions outlined in the agency agreement.
2. Where possible, Seneca will support terminations with available corroborating evidence secured from documented investigative and/or corrective efforts.
3. Seneca will provide written notification of the termination to the agency, including the grounds for the decision.

1. Seneca securely stores digital records of contracted agencies in a central location. Access to this data will be limited to Seneca employees and other authorities as assigned by Seneca and/or as required by legislation.

1. In accordance with the Conflict of Interest policy, employees must disclose any relationship with a prospective or current agency that may create a real and/or perceived conflict to their direct supervisor and the Seneca Compliance Office.
2. In accordance with the Anti-Nepotism policy, employees cannot directly or indirectly supervise agencies with whom they have familial or personal relationships. Supervisory activities include engaging in disciplinary or evaluative functions.

1. Employees may accept a gift of nominal value (valued at less than $100 CAD) from an agency if it is customarily offered to others who have similar relationships. Solicitation of gifts is strictly prohibited.
2. Employees are prohibited from soliciting, requesting or receiving bribes, improper payments or other inducements.
3. Employees may accept entertainment from a Seneca-certified agency, provided the total cost does not exceed $100 CAD per person per event.
4. Employees shall direct agency donations to Seneca Advancement and Alumni.

• Agency Code of Conduct (PDF)

• Anti-Nepotism Policy
• Anti-Money Laundering and Sanctions Policy
• Conflict of Interest Policy
• Discrimination and Harassment Policy
• Freedom of Information and Protection of Privacy Policy
• Gift Acceptance Policy
• Procurement Policy
• Sexual Violence Policy

• None

Approval Date: September 2022