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Associate Professor Jason Hartley

Jason Hartley is lecturer in criminology at Griffith University in Brisbane, Australia. He is a former police officer with 23 years of experience, and has trained personnel for deployment in Timor Leste, the Solomon Islands, Iraq and Afghanistan. Jason specializes in, and has published on engagement with Muslim communities, Indigenous Polynesian approaches to rehabilitation and reducing recidivism, and Asian Organised Crime. Jason also completed a community internship in Hebron on the West Bank.

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Dr Shantanu Banerjee

Dr Shantanu Banerjee is senior lecturer at Leaders Institute. With extensive experience in management, leadership, and administration across a range of contexts in India and Australia, Dr Banerjee is also currently an Industry Fellow at the University of Queensland Business School. His research focuses on socio-cultural-political contexts, particularly in the field of agribusiness and international business. His research has highlighted variations in the theme of international competitiveness by emphasising non-economic and non-market variables and on how multinational enterprises subsidiaries can pursue legitimacy pursuing non-market strategies.

Dr Banerjee has presented his research work at esteemed international conferences such as ANZIBA and EIA and has published in scholarly journals including International Business Review and Management International Review. He graduated from the Institute of Foreign Trade, New Delhi (India) and the University of Queensland Business School. He has been an academic staff member at the University of Queensland and Queensland University of Technology, lecturing in undergraduate and postgraduate programs. Dr Banerjee has over 15 years of extensive and varied experience as an International Business Manager dealing and negotiating with overseas clients based in the United States of America, China, Japan, Canada, Switzerland, and Germany. He is currently employed with a Federal agency of the Australian Treasury.

Qualifications

Doctor of Philosophy, University of Queensland, 2012

Master of Research, Queensland University of Technology, 2005

Master of Business, Queensland University of Technology, 2003

Postgraduate Diploma in International Trade, Indian Institute of Foreign Trade, 1986

Bachelor of Mechanical Engineering

Indian Institute of Foreign Trade, 1985

Communities of Practice

Editorial Board, Academy of International Business
Editorial Board, European Academy of Management
Editorial Board, Leadership & Management Studies in Sub-Sahara Africa Conference
Editorial Board, International Journal of Entrepreneurship and Small Business

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Associate Professor Ben Arachi

BIOGRAPHY

Associate Professor Ben Arachi has four decades (1977-2023) of experience in higher education leadership and teaching. During his 15 years as Unit Coordinator at Central Queensland University, he received two Excellence in Teaching Awards and was nominated for the Vice-Chancellor’s Award for Outstanding Contributions to Learning and Teaching and the Australian Awards for University Teaching. His online learning study was published in Economics for Today (Cengage 2022).

Previously, Associate Professor Arachi served as Vice Principal, Head of the Department of Extension and Research, and Editor-in-Chief of the academic journal at Arul Anandar College, India (1992-1997). He was then Research Coordinator and Course Coordinator (1999-2008), as well as Chair of the Division of Economics (2000-2005) at HELP University, Malaysia. This included senior involvement in the application to become a University College and then a full University.

Associate Professor Arachi also has over 20 years of experience as a higher degree research supervisor, moderator, and examiner for doctoral degrees. In his five years as a Coordinator of All India Christian Higher Education, he organised numerous state-level seminars and workshops for academics in higher education in India. He has published four monographs, many research papers and articles while editing the Research AAC Journal of Economics. He has reviewed many higher education textbooks.

QUALIFICATIONS

Doctor of Philosophy, Madursi Kamaraj University, India, 1989
Master of Arts, University of Madras, 1975 (Gold Medalist)
Bachelor of Arts, Madursi Kamaraj University, India, 1973 (University Rank and Merit Scholarship)
Diploma in Applied Economics, Madursi Kamaraj University, India, 1980

ACADEMIC LEADERSHIP

Member, Academic Board, 2023-current
Chair, Examiners Committe, 2023-current
Member, Course Advisory Committee, 2022-current

AWARDS

Central Queensland University Student Voice Commendation. The 2021 program includes unit evaluation data from term 3, 2020 and terms 1 and 2, 2021.
Central Queensland University Student Voice Commendation. The 2020 program includes unit evaluation data from term 3, 2019 and terms 1 and 2, 2020.
Central Queensland University Central Queensland University Platinum certificate Top rated Unit in Term 2, 2019
Central Queensland University Gold certificate Highly rated Unit in Term 2,2019 (ACCT20070)
Gold certificate Highly rated Unit in Term 2,2019 from CQU(ECON11026)
Charles Sturt University Excellence in Teaching Award (ECO511)

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Agent Appointment, Monitoring and Termination Policy

PURPOSE
This policy details Global Leadership Institute’s (GLI) processes in the appointment, monitoring, review, and termination of education agents who represent the Institute.

SCOPE
All education agents

PRINCIPLES
An education agent is a person or organisation (offshore or onshore) who recruits international students and refers them to GLI. In doing so, the education agent may provide education counselling to international students as well as marketing and promotion services to the Institute.

GLI abides by all relevant regulations regarding education agents, including but not limited to:

The Institute ensures that:

Memorandums of Understanding (MOUs) are only accepted from education agents registered with the Migration Agents Registration Authority;

MOUs with education agents are only accepted when service activities have been agreed to and a written agreement is ratified and signed by the President or delegated representative;

GLI adheres to and takes corrective action with an agent that is not performing satisfactorily or does not comply with the terms of the agent agreement in accordance with relevant legislation and requirements of the National Code;

education agents are not teaching at GLI;

all reasonable measures are taken to use education agents that have an appropriate knowledge and understanding of the Australian international education industry, the ESOS Act and Regulations 2000, the Australian International Education and Training Agent Code of Ethics, as well as GLI’s accredited courses;

all education agents engaged by GLI are required to read and be aware of the regulations regarding international students as stipulated in The National Code 2018;

GLI and its education agents market all courses with integrity, accuracy, and professionalism, avoiding vague and ambiguous statements;

GLI’s information has no false or misleading comparisons with another education provider or course;

GLI and its education agents provide accurate and consistent information regarding the Australian Qualifications Framework (AQF), GLI’s course accreditations, and scope of registration in all marketing and advertising;

GLI and its education agents provide marketing information and advice regarding payment of fees that is accurate and fair, allowing students or prospective students to make enrolment and payment decisions with a clear understanding of their rights and obligations. The Institute will not offer any prohibited inducements;

GLI and its education agents do not actively recruit students enrolled with another provider. Applications and enrolments from international students will be processed as set out in the Student Admission Policy;

GLI and its education agents only use logos belonging to another body in accordance with their conditions of use;

GLI does not use education agents who are dishonest or lack integrity;

written agreements are signed with education agents, including specific responsibilities;

student applications from or agreements with agents will not be accepted if GLI knows, or reasonably suspects, that

they are:

engages or previously engaged in dishonest practices;
deliberately facilitating application of a student that clearly conflicts with Standard 7 of the National Code;
facilitating application of a student who the education agent believes will not comply with the conditions of the student visa;
using the Provider Registration and International Students Management System (PRISMS) to create Confirmation of Enrolments (CoEs) for other than genuine students; or
providing immigration or migration advice where not authorised to do so under the Migration Act 1958;

GLI and its education agents do not give false or misleading information and advice regarding:

claims of association between providers;
the employment outcomes associated with a course;
automatic acceptance into another course;
possible migration outcomes;
any other claims relating to GLI, its courses, or outcomes associated with its courses;
payment options.

EDUCATION AGENT WRITTEN AGREEMENT
GLI ensures that the Education Agent Written Agreement includes:

responsibilities of the registered provider, including compliance with the ESOS Act and National Code 2018
responsibilities of the agent in representing the Institute;
clear explanations regarding monitoring and correcting;
termination conditions (immediate upon failure to meet the National Code 2018 or Migration Act 1958);
circumstances under which information about the education agent may be disclosed.

Credit Card Marketing
The advertising, marketing, or merchandising of credit cards directed at students is prohibited at GLI. The Institute also prohibits the provision of student or prospective student information to credit card companies for the purpose of offering credit cards to those students.

MONITORING
GLI monitors education agents through:

weekly marketing reports to the President;
monthly marketing reports to Executive Management Team;
quarterly marketing reports to Academic Board and Governing Board;
Annual Performance Review of Education Agents;
regular communication of Marketing Managers with education agents;
student surveys;
data from PRISMS;
performance and progression of students.

DISMISSAL
GLI takes immediate corrective action or dismisses an agent in writing if the agent is negligent, careless, incompetent, dishonest, or unethical. This includes the deliberate attempt to recruit a student where this clearly conflicts with the obligations of registered providers under National Code Standard 7. GLI may also terminate an agent agreement if a visa application for a student referred by the agent is refused by Department of Home Affairs for reasons related to fraudulence or suspicion of fraud.

Any GLI staff member who becomes aware of possible breaches of this policy must report it to their supervisor. Any GLI staff member or student who violates this policy will be subject to formal disciplinary action. Penalties may range from restriction from campus or in some more serious instances criminal or civil proceedings. GLI will report illegal activities and corrupt conduct to appropriate authorities.

PROCEDURES

APPOINTMENT
Prospective education agents for GLI must meet the following criteria:

appropriate knowledge and understanding of the international education system in Australia, including the ESOS Act, National Code, Australian International Education and Training Agent Code of Ethics;
track record of recruitment and marketing activities with honesty and integrity;
experience in recruitment of genuine students for Australian higher education institutes;
appropriate training regarding acting as an education agent for Australian higher education institutes;
completed Education Agent Application Form, including two referees from Australian higher education institutes, a certified copy of their business registration or license, and details of proposed fees and charges (if applicable).

WRITTEN AGREEMENT
GLI ensures that the written Agent Agreement includes:

responsibilities of the registered provider, including compliance with the ESOS Act and National Code 2018
responsibilities of the agent in representing GLI;
clear explanations regarding monitoring and correcting;
termination conditions immediate upon failure to meet the National Code 2018 or Migration Act 1958;
circumstances under which information about the education agent may be disclosed.

TRAINING
GLI provides ongoing training to its education agents, including:

induction for newly appointed education agents;
information updates and training when there are changes to legislative and/or regulatory requirements, GLI policies, and/or course changes, including fee structures; and corrective training to address any shortcomings in the education agent’s performance identified through GLI monitoring;
regular contact with education agents by phone, email, newsletters, and visits to education agents’ offices to provide up-to-date and accurate information on courses and marketing materials to enable them to conduct their business;
encouragement for education agents to undertake online PIER training to familiarise themselves with relevant legislative and regulatory requirements. Where possible, education agents will be invited to visit GLI for familiarisation.

MONITORING PROCEDURES
GLI’s Marketing Manager monitors education agents on an ongoing basis which includes but is not limited to:

collection, collation, and analysis of relevant statistical data, including: offer to conversion rates; student visa refusal rates; adherence to GLI admission processes; performance and progression of students through the course; and other relevant data from PRISMS;
ensuring that education agents below the 75% visa-grant benchmark for two consecutive student intakes enter “corrective action” with mandatory re-training. Chronic under-performance triggers contract termination;
GLI staff spot checks through face-to-face visits to education agents or contact via phone, email, or other means;
student surveys;
student or prospective student feedback/complaints (formal/informal) including claims of engaging in misleading conduct;
regularly reviewing the education agent’s website for accuracy and currency of information relating to GLI;
feedback from a relevant Australian government departments;
Annual Performance Review of education agents to ensure they are meeting agreed Key Performance Indicators and complying with all legislative requirements.

GLI determine from time to time whether, and if so, what, corrective action to implement if an education agent fails to comply with the Agent Agreement. The Institute will take immediate corrective action if it becomes aware, or has reason to believe, that the education agent has not:

declared and taken reasonable steps to avoid conflicts of interests;
observed confidentiality and transparency in its dealings with overseas students or prospective students;
acted honestly and in good faith and in the best interests of the student;
demonstrated an appropriate understanding of the international education system in Australia, including the Agent Code of Ethics.

CORRECTIVE ACTION
Depending on the circumstances, corrective action may include providing the education agent with additional information, clarifying GLI’s expectations, additional or target training on expectations of the education agent, counselling, written warning(s), or termination of the Agent Agreement.

Where GLI becomes aware of an education agent behaving in an unethical and/or non-compliant manner as indicated in the Agent Agreement, GLI will terminate the agreement.

RENEWING AND TERMINATING
Following the education agent’s Annual Performance Review, GLI may:

renew the appointment;
renew the appointment subject to certain conditions, such as a requirement for further training or an improvement in referral, conversion, and success rates;
terminate the appointment.

The Institute will immediately terminate an Agent Agreement in writing if:

GLI becomes aware of, or reasonably suspects negligent, careless, incompetent, unethical, or dishonest recruitment practices, including engaging in false or misleading practices, and a deliberate attempt to recruit a student where this clearly conflicts with the obligations of registered providers under the ESOS Act and the National Code;
a visa application for a student referred by the education agent is refused by the Department of Home Affairs for reasons related to fraudulence or suspicion of fraud;
GLI becomes aware of any of the other dishonest or criminal practices committed by the education agent;
the education agent breaches the Agent Agreement;
GLI is directed or required to terminate the arrangement by a relevant Australian government department.

If the Marketing Manager or delegated authority decides to terminate an education agent’s appointment, the Marketing Manager will:]

write to the education agent to advise that their appointment has been terminated using the agent termination letter;
advise staff that no further applications are to be accepted from the agent.

REPORTING
Any GLI staff member who becomes aware of possible breaches of this policy must report it to their supervisor. Any staff member or student who violates this policy will be subject to formal disciplinary action. Penalties may range from restriction from campus or in some more serious instances criminal or civil proceedings. GLI will report illegal activities and corrupt conduct to appropriate authorities.

GLI will notify the relevant Australian government departments of the termination of an Agent Agreement and the grounds for termination if it resulted from suspected criminal conduct. Details relating to the review and decision will be entered on the education agent’s file. The education agent’s name will be removed from the GLI website. The education agent’s students will be notified of the termination/non-renewal and be invited to submit a change of agent request and no further referrals and applications will be accepted from the terminated education agent.

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Agent Appointment, Monitoring and Termination Policy

Fact Box

Owner : President

Approval Body : Executive Management Team

Endorsement Body : Executive Management Team

Category : Management

Approval Date : 10 July 2025

Review Date : 10 July 2030

Version : 2.0

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