Anti-Bribery and Anti-Corruption Policy

WorldStudentAdvisors
Last reviewed: January 2026
Approved by: Managing Director
Next review: January 2027 or earlier if legislation or sector guidance changes

1. Policy Statement

WorldStudentAdvisors (“WSA”) is committed to conducting all business dealings ethically, transparently, and in full compliance with applicable anti-bribery and anti-corruption laws.

WSA operates a zero-tolerance approach to bribery and corruption. We prohibit the offering, giving, requesting, or accepting of any bribe, facilitation payment, inducement, or improper advantage of any kind, whether financial or non-financial, to or from any person or organisation.

2. Scope of the Policy

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 carried out in the United Kingdom and internationally.

3. Legal and Regulatory Framework

This policy is designed to ensure compliance with:

• The UK Bribery Act 2010
• All associated guidance issued under the Bribery Act 2010
• Other applicable UK legislation relating to bribery and corruption
• Any similar or equivalent legislation in jurisdictions in which WSA operates
• Contractual obligations imposed by UK university partners

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

4. Definition of Bribery

A bribe is any financial or other advantage offered, promised, given, requested, or received with the intention of inducing or rewarding improper performance of a function or activity.

Bribery can include (but is 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, secret commissions, or undisclosed incentives
• Improper gifts or hospitality intended to influence decisions
• Any attempt to improperly influence admissions decisions, visa outcomes, or academic processes

No individual acting on behalf of WSA will be penalised for refusing to engage in bribery, even if such refusal results in a loss of business or opportunity.

6. Gifts and Hospitality

Reasonable and proportionate hospitality may be offered or accepted only where:

• It is infrequent and modest in value
• It is not intended to influence a business decision
• It complies with university partner policies
• It is transparent and appropriate in the circumstances

Cash or cash-equivalent gifts are never permitted.

7. Third Parties, Agents, and Representatives

WSA undertakes due diligence on all agents, representatives, and partners. All third parties acting on behalf of WSA must:

• Agree to comply with this policy
• Operate transparently and ethically
• Not offer or accept bribes or inducements

WorldStudentAdvisors remains fully responsible for the conduct of its representatives, agents, and sub-contractors in accordance with university partner agreements.

Any breach of this policy by a third party may result in immediate termination of the relationship.

8. Responsibilities

Managing Director

• Holds overall responsibility for this policy
• Reviews the policy annually
• Ensures compliance across all WSA operations

Staff and Representatives

• Must read, understand, and comply with this policy
• Must report any suspected or actual bribery or corruption immediately

9. Reporting Concerns

Any concerns or suspicions regarding bribery or corruption must be reported promptly and in confidence to:

Managing Director
WorldStudentAdvisors
Email: tim.hunt@worldstudentadvisors.com

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

10. Breaches of This Policy

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 and Review

This policy is reviewed:

• Annually
• When relevant legislation or sector guidance changes
• When required by university partners or regulatory bodies

Updates are communicated internally and embedded within operational procedures, staff briefings, and partner guidance.

12. Publication

This policy is publicly available on the WorldStudentAdvisors website and may be provided to university partners, auditors, or regulators upon request.

Timothy J Hunt
Managing Director
WorldStudentAdvisors

WorldStudentAdvisors is committed to ethical recruitment practices, transparency, and full compliance with UK and international standards.