House of Admissions’ conflict of interest policy. HOA charges students nothing and is paid commission by a UK partner university when a student enrols. The policy addresses three risks — partner bias, commission-rate bias and counsellor incentive bias. Its central control is that no counsellor’s pay varies by which university a student chooses.
Conflict of Interest Policy
HOA is paid by universities and free to students. That is a real conflict of interest. This policy sets out the three ways it could distort advice and what is done about each.
Key points
- Students pay nothing. HOA is paid a commission by a UK partner university when a student it introduced enrols there.
- No counsellor earns more for one university than another. No pay, bonus, target or benefit varies by where a student enrols.
- No counsellor may accept any payment or gift from a university, in any amount.
- Non-partner universities must be named where they are a materially better fit, even though HOA earns nothing from them.
- Shortlists are built before commission is considered, and each university on one carries a recorded reason tied to the student’s criteria.
- Placement distribution is reviewed annually so that drift can be detected rather than assumed absent.
- HOA is AQF-aligned, not AQF-registered — no such registration exists for agencies.
1 The conflict, stated plainly
House of Admissions charges students nothing. HOA is paid a commission by a UK partner university when a student it introduced enrols there. That is the whole business model, and it creates a conflict of interest that no policy can abolish: the organisation advising a student on where to study is paid according to where that student goes.
This policy exists because the conflict is real, not because it is theoretical. It sets out the three specific ways that conflict could distort advice, and what HOA does about each.
A 2026 review by the Higher Education Policy Institute found that around a third of UK university websites examined did not explain how agents are compensated, and that where disclosure existed it was often “partial, uneven or framed in ways that minimise the commercial nature of the relationship”.
HOA’s position is that a student cannot weigh advice without knowing how the adviser is paid. The paragraph above is the disclosure, in the plainest terms available.
Higher Education Policy Institute, analysis of agent transparency, May 2026.2 The three risks this policy addresses
| Risk | What it would look like | Control |
|---|---|---|
| Partner bias | Steering a student to a partner university when a non-partner institution fits them better | Section 4 — non-partner options must be named |
| Rate bias | Favouring partners that pay a higher commission | Section 5 — shortlists are built before commission is considered, and reasons are recorded |
| Counsellor incentive bias | An individual counsellor earning more for placing a student at one university than another | Section 3 — the central control in this policy |
3 Counsellor pay is not differential by university
This is the most important commitment in this document, because it is the point at which an institutional conflict becomes a personal one.
- No counsellor’s pay, bonus, commission, target, ranking or any other benefit varies according to which university a student enrols at.
- No counsellor receives any payment, gift, trip, voucher or benefit directly from a university, in any amount, at any time. Payments are made to HOA, not to individuals.
- No university-specific placement targets are set for any counsellor or office.
If a counsellor earns the same whether a student goes to University A or University B, the main reason to prefer one over the other is that it suits the student. That is the point. Any incentive scheme HOA introduces in future must satisfy this rule before it is adopted, and the policy owner is responsible for testing it against this section.
Soliciting or accepting a personal payment or benefit from a university, or steering a student for personal gain, is gross misconduct and may also be a criminal matter. It is reportable under the Complaints and Appeals Policy, including by the student.
4 Non-partner universities must be named
HOA works with a defined set of UK partner universities. It does not work with every UK institution, and for some students the best option is one HOA earns nothing from.
- Where a non-partner university is a materially better fit on course, entry requirements, cost or location, the counsellor names it, explains why, and records that it was discussed.
- HOA will tell a student plainly when it cannot support an application to an institution, and will not disguise that limitation as a recommendation against it.
- A student is free to apply anywhere, with or without HOA, and will not be refused continuing help for doing so.
- Every shortlist states which universities on it are HOA partners.
HOA’s knowledge of partner universities is deeper than its knowledge of institutions it does not work with, simply because of contact and volume. A student should weigh HOA’s advice accordingly, and is encouraged to check any shortlist against independent sources such as UCAS, the universities’ own websites, and the Office for Students register.
5 How a shortlist is built
- The counsellor establishes the student’s academic profile, budget, course and location preferences, and visa position first.
- A shortlist is drawn against those criteria. Commission rates are not a criterion and are not consulted at this stage.
- Each university on the shortlist carries a recorded reason tied to the student’s stated criteria.
- Partner status is disclosed on the shortlist.
- The student chooses. HOA does not submit an application the student has not agreed to.
6 Gifts, hospitality and university visits
- Modest hospitality in a professional context — refreshments at a university event, a working lunch — is acceptable and does not need recording.
- Anything beyond that, including travel, accommodation, electronics, vouchers or cash of any value, is declined, or where declining is impractical, accepted on behalf of HOA and entered in the gifts and hospitality register.
- University-funded familiarisation trips are accepted only by HOA as an organisation, are recorded, and create no obligation to recommend that institution. A counsellor who has attended one discloses that fact when recommending that university.
- The register is reviewed by the policy owner at least annually.
7 Personal interests and recusal
A member of staff must declare, in writing to the policy owner, any of the following, and withdraw from advising that student or dealing with that institution:
- A family or close personal relationship with a student they would otherwise advise.
- Any financial interest in, employment by, or paid relationship with a university, accommodation provider, test centre, bank, loan provider or travel agent.
- Any arrangement under which they would receive a benefit for referring a student to a third party, including IELTS or PTE centres, medical or TB testing providers, or forex services.
Declaring an interest is not an accusation and carries no penalty. Failing to declare one does.
8 Placement concentration review
A policy that relies only on good intentions cannot detect drift. Once a year the policy owner reviews the distribution of HOA placements across universities.
Where an unusually high proportion of students has gone to one institution, that is not itself wrong — it may simply reflect course fit or entry requirements for the profile of students HOA sees. But it is a question that must be asked and answered in writing, and the answer must be something other than the commission rate. The review and its conclusion are recorded.
9 What HOA will not do
- Charge a student any fee, at any stage, for any service.
- Accept payment from a university in return for recommending it to a specific student.
- Enter an exclusivity arrangement that would prevent HOA presenting a student with a competing university.
- Submit an application to any institution without the student’s agreement.
- Write a student’s personal statement, which is a separate commitment set out in the Student Service Charter.
- Withhold information about a university’s status — including a suspended or revoked sponsor licence — from a student it affects.
10 Alignment with sector standards
This policy is written to be consistent with the four principles of the UK Agent Quality Framework, a sector-wide initiative led by the British Council with BUILA, UKCISA and Universities UK International:
- empowering student choice and enabling informed decision making;
- ensuring good agent governance and professionalism;
- promoting ethical agent practices, professional knowledge and competency;
- increasing transparency and accountability.
The National Code of Ethical Practice for UK Education Agents sits at the heart of that framework, which in turn follows the London Statement of 2012 on the ethical recruitment of international students.
HOA describes its practice as AQF-aligned. It is not “AQF-registered” and no such registration exists for agents: the AQF sets standards by which UK education providers manage their agents, and explicitly does not accredit or license agencies. Any consultancy claiming AQF registration, or UKVI certification, is claiming a credential that does not exist.
11 Raising a concern under this policy
A student, parent, university or member of staff who believes advice has been influenced by commission rather than by the student’s interests should raise it through the Complaints and Appeals Policy. Concerns of this kind go directly to Stage 2, because they are not suited to informal resolution by the counsellor involved.
A member of staff who raises such a concern in good faith will not be penalised, whatever the outcome of the investigation.
Questions about this policy
A UK partner university pays HOA a commission when a student HOA introduced enrols there. Students pay nothing at any stage. That arrangement is the reason this policy exists: the organisation advising a student on where to study is paid according to where that student goes, which is a real conflict of interest and not a theoretical one.
No. No counsellor’s pay, bonus, target, ranking or any other benefit varies according to which university a student enrols at, and no counsellor may accept any payment or gift directly from a university. This is the central control in the policy, because it is the point where an institutional conflict would otherwise become a personal one.
Yes. Where a non-partner university is a materially better fit on course, entry requirements, cost or location, the counsellor must name it, explain why, and record that it was discussed. HOA earns nothing in that case. Every shortlist also states which universities on it are HOA partners, so you can see where the commercial relationship lies.
HOA’s knowledge of partner universities is deeper than its knowledge of institutions it does not work with, simply because of contact and volume. That is a real limitation and the policy states it rather than denying it. Students are encouraged to check any shortlist against independent sources such as UCAS and the universities’ own websites.
Rates are set in commercial agreements between HOA and each university and vary. The fact that commission is payable is disclosed to every student as a matter of course. A student who wants to know whether a specific recommendation was influenced by rate can ask for the recorded reason behind their shortlist, which must be tied to their own stated criteria.
Three things that produce evidence rather than intentions: each shortlist carries a recorded reason per university; gifts and hospitality beyond modest refreshments are entered in a register reviewed annually; and once a year HOA reviews how its placements are distributed across universities, with any unusual concentration explained in writing by something other than the commission rate.
No, and no agency is. The AQF sets standards by which UK education providers manage their agents and explicitly does not accredit, license or register agencies. HOA describes its practice as AQF-aligned, which is a description of how it works rather than a credential. Any consultancy claiming AQF registration or UKVI certification is claiming something that does not exist.
Raise it under the Complaints and Appeals Policy. Concerns of this kind go directly to Stage 2 rather than being handled informally by the counsellor involved, and are acknowledged within 2 working days with a full response within 10 working days.
Ownership, adoption and review
- Policy owner
- Kabir Panta, Safeguarding and Compliance Officer — compliance@houseofadmissions.com
- Deputy
- Anusha Budhathoki — apply@houseofadmissions.com
- Adopted by
- Rahul Chhetri, Director on 2 October 2026
- Version
- 1.0, issued 2 October 2026
- Next review
- By 2 October 2027, or immediately on any material change to HOA's partner agreements, counsellor pay arrangements, or applicable law
Published by House of Admissions, a UK-exclusive education consultancy in Nepal, free to students at every stage. This document is not legal advice. Related: Student Service Charter · Complaints & Appeals Policy · Conflict of Interest Policy · Safeguarding Policy · All legal documents.