Centre for Open Learning

COL Code of Practice for Appointed Overseas Representatives

COL requires all agents to adhere to the COL Code of Practice for Appointed Overseas Representatives.


  1. Representatives shall at all times conduct themselves with integrity and in a manner that will reflect positively on the image of their profession and COL as reliable and trustworthy providers of high-quality education and training. This standard of conduct underpins the others that follow and encompasses all aspects of Representatives’ activities.
  2. Representatives shall promote themselves and COL in a professional and ethical manner and shall ensure that their business facilities and activities reflect the highest standard. This standard of conduct refers both to ethical behaviour and to standards of professionalism. Best practice means that a representative’s business activities should not be of a kind that might bring discredit on COL or UK education generally.
  3. Representatives shall be honest in communicating information about themselves, COL and potential students in published, oral or any other form. They shall not knowingly or by a failure of professional standards provide or disseminate false, incomplete or misleading information. This standard of conduct is closely related to clause 2.3 and refers to any information released by a Representative on behalf of COL about facilities, entry requirements, admissions processes, course content, fees or any other matter. All claims made by a Representative about itself, COL, or students shall be capable of being substantiated. This standard of conduct also applies equally to information provided about potential students in applications to COL and visa authorities. In particular, information provided to potential students shall be sufficient to enable them to make an informed judgement. The inclusion of the word ‘incomplete’ in this standard is especially important: Representatives shall not in published or orally delivered information omit any fact which may reasonably be of material relevance to an international student, where an omission might be construed as being misleading. The accidental production or dissemination of incorrect or incomplete information is likely to be viewed in itself evidence of a failure to adhere to professional standards, except where there is compelling evidence to suggest otherwise. In summary, this standard requires Representatives to provide full, honest and accurate information about COL and the courses and facilities it offers.
  4. Representatives shall promote themselves and COL fairly and without recourse to unfavourable or negative comparisons with other institutions, or otherwise employ unfair or unprofessional practice to damage the interests of other institutions. This standard of conduct refers to any attempt by Representatives to gain advantage for their clients by using information about other institutions negatively. Using verifiable data to show the standing of COL in relation to others is acceptable, but this practice shall not be executed in such a manner as to discredit other institutions. This means Representatives should promote products by focusing on the strengths and achievements of COL rather than by making unfavourable comments about competitors.
  5. Representatives shall act at all times in the best interests of students or prospective students as well as COL. They shall offer advice and counselling and provide information to students, and where appropriate their parents/advisors, in a manner consistent with this principle. This standard of conduct is fundamental to good practice in education marketing and student recruitment. It refers not only to truthfulness and accuracy, but also to appropriateness. An example of inappropriate advice would be the encouragement of a student to enter a course of study for which they were inadequately prepared in terms of language proficiency or academic attainment. The standard also includes advice or information given to sponsors of students and other such bodies or persons as well as directly to students. Again, the omission of salient information in an effort to secure the placement of a student is likely to be judged as a breach of this standard.
  6. Representatives shall undertake to provide clear details both to students and to COL of any charges made to students for services offered by the Representative. In particular, Representatives shall make it clear to students that these fees are charged by the Representative and not COL. Furthermore, Representatives shall emphasise to students that the payment of a fee to the Representative will not in any way affect the likelihood of the student being made an offer by COL.
  7. Representatives shall conduct themselves with due regard to the regulatory conditions in the market(s) in which they operate. They shall comply with all applicable national laws, regulations and official policies.
  8. Representatives shall conduct themselves with due regard to the need for transparency and openness in all their dealings with and on behalf of COL. With reference to clause 2.1.7 Representatives should comply with all applicable laws, statutes, regulations and codes relating to anti-bribery and anti-corruption including but not limited to the Bribery Act 2010.