Anti-Bribery & Anti-Corruption Policy

WorldStudentAdvisors maintains a zero-tolerance approach to bribery and corruption in all forms. This policy defines the standards expected of all individuals representing the organisation and establishes the controls in place to prevent, detect, and respond to any form of corrupt activity.

WorldStudentAdvisors is committed to conducting all activities with integrity, transparency, and in full compliance with the UK Bribery Act 2010 and applicable international anti-corruption legislation.

This policy applies to:

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

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

This policy is aligned with:

• UK Bribery Act 2010
• Applicable international anti-corruption legislation
• British Council Agent Quality Framework (AQF)
• University partner compliance requirements

Bribery: Offering, promising, giving, requesting, or accepting a financial or other advantage to induce or reward improper performance of a function or activity.

Corruption: The misuse of entrusted power or position for private gain, including but not limited to bribery, fraud, extortion, and conflicts of interest.

Facilitation payments: Small unofficial payments made to secure or expedite routine actions. These are prohibited under this policy regardless of local custom or practice.

The following activities are strictly prohibited:

• Offering, promising, or giving any bribe or improper inducement
• Requesting or accepting any bribe or improper inducement
• Making facilitation payments of any kind
• Offering gifts, hospitality, or payments intended to influence decisions
• Misrepresenting student credentials, qualifications, or documentation
• Falsifying records, reports, or compliance documentation
• Engaging in any activity that could reasonably be perceived as corrupt

WorldStudentAdvisors recognises that modest gifts and hospitality may form part of normal business relationships. However:

• Gifts or hospitality must never be offered or accepted where they could influence or be perceived to influence a business decision
• Gifts or hospitality of significant value must be declared and approved
• Cash payments or cash equivalents are never acceptable

WorldStudentAdvisors applies proportionate due diligence to third parties, including:

• Assessment of third-party relationships prior to engagement
• Contractual obligations requiring compliance with anti-bribery standards
• Ongoing monitoring of third-party conduct

Any individual who suspects or becomes aware of bribery or corruption must report the matter immediately to the Managing Director.

Reports may be made in confidence and without fear of retaliation. WorldStudentAdvisors will not tolerate any form of victimisation against individuals who raise genuine concerns in good faith.

Any breach of this policy will be treated as a serious matter and may result in:

• Disciplinary action, including termination of employment or contract
• Termination of partnership or agency agreements
• Referral to relevant authorities where criminal conduct is suspected

WorldStudentAdvisors monitors compliance through:

• Internal review of financial transactions and third-party relationships
• Case file audits and documentation checks
• Feedback from partners and stakeholders

This policy is reviewed periodically to ensure alignment with legislation, partner expectations, and sector best practice.