Code of Conduct

Global Pathway Partners (GP2)
Expected standards of conduct for everyone representing Global Pathway Partners

1. Purpose and Scope

This Code of Conduct establishes the minimum standards of professional, ethical and responsible behaviour expected of all directors, employees, contractors, consultants, representatives, agents and partners of Global Pathway Partners (GP2).

Everyone acting on behalf of GP2 is expected to comply with this Code, applicable laws and regulations, and relevant GP2 policies and procedures. The Code is intended to promote integrity, transparency, professionalism and respectful relationships with students, colleagues, education providers, suppliers and other stakeholders.

2. Respect, Dignity and Equal Treatment

GP2 is committed to maintaining a professional environment in which everyone is treated with dignity and respect.

All representatives of GP2 must:

• Treat students, colleagues, partners and other stakeholders fairly and respectfully.
• Communicate professionally and courteously.
• Not engage in harassment, bullying, discrimination, intimidation, threatening behaviour or abusive language.
• Not misuse their position, authority or influence.
• Respect differences in background, identity, culture, beliefs and circumstances.

Any conduct that undermines a safe, respectful and professional environment is unacceptable.

3. Honest and Transparent Student Communication

Students must receive information that is clear, accurate and presented in a manner they can reasonably understand.

GP2 representatives must:

• Provide information based on available and reliable sources.
• Clearly distinguish confirmed information from general guidance, estimates or opinions.
• Avoid misleading, exaggerated or deceptive statements.
• Never guarantee admission, scholarships, visas, employment, immigration outcomes or other results that are outside GP2’s control.
• Clearly communicate relevant requirements, limitations, conditions and potential risks where appropriate.
• Correct material errors or misleading information promptly when identified.

Our communications should enable students to make informed decisions about their education and related services.

4. Acting in the Student’s Interests

Student needs and circumstances should be considered when providing information, guidance and referrals.

GP2 representatives must:

• Take reasonable care to ensure information and referrals are relevant to the student’s stated interests, circumstances and objectives.
• Avoid presenting commercial interests as independent advice.
• Clearly communicate relevant commercial relationships where disclosure is appropriate.
• Never allow commissions, incentives, referral arrangements or other commercial considerations to override honest and transparent communication.
• Respect a student’s right to make their own informed decisions.

5. Confidentiality and Privacy

GP2 respects the privacy and confidentiality of personal and business information.

All representatives must:

• Collect and use personal information only for legitimate and authorised purposes.
• Handle personal information in accordance with applicable privacy and data-protection requirements.
• Take reasonable measures to protect confidential information against unauthorised access, disclosure, alteration or loss.
• Share personal or confidential information only with appropriate consent or where there is another lawful basis to do so.
• Avoid discussing confidential student, employee or business information with unauthorised persons.
• Report suspected data breaches or inappropriate disclosure promptly through the appropriate channel.

Confidentiality obligations may continue after an individual’s employment, engagement or partnership with GP2 ends.

6. Conflicts of Interest

Everyone representing GP2 must act honestly and avoid situations in which personal interests could improperly influence professional judgement.

Any actual, potential or perceived conflict of interest should be disclosed promptly to the appropriate GP2 management or compliance contact.

Representatives must not:

• Use their position with GP2 for improper personal or financial benefit.
• Use confidential information obtained through their work for personal advantage.
• Allow personal relationships or financial interests to improperly influence decisions involving students, providers, suppliers or partners.

Where a conflict exists, appropriate steps should be taken to manage or resolve it fairly and transparently.

7. Gifts, Bribery and Improper Payments

GP2 has zero tolerance for bribery, corruption and improper payments.

Representatives must not offer, promise, request, authorise or accept:

• Bribes or kickbacks;
• Facilitation payments;
• Secret commissions;
• Improper financial or non-financial benefits; or
• Gifts or hospitality intended to improperly influence a business decision.

Gifts and hospitality must be reasonable, lawful, transparent and appropriate to the circumstances.

All representatives must comply with GP2’s Anti-Bribery and Corruption Policy and applicable anti-corruption laws.

8. Professional Relationships

GP2 representatives are expected to maintain professional and respectful relationships with education providers, institutions, suppliers, competitors and other business partners.

Representatives must:

• Communicate honestly and professionally.
• Respect confidential and commercially sensitive information.
• Avoid making false, misleading or defamatory statements about another organisation or individual.
• Not seek or use confidential information through improper means.
• Represent GP2’s relationships, partnerships and business arrangements accurately.

9. Accurate Records and Documentation

GP2 expects business records and documentation to be accurate, complete and maintained appropriately.

Relevant records may include:

• Student referrals and relevant consent records;
• Commission and referral records;
• Business expenses;
• Agreements and correspondence;
• Communications with students and partners; and
• Other records required for legitimate business, compliance or reporting purposes.

Records must not be falsified, deliberately concealed or improperly altered.

GP2 does not receive or process student tuition payments. Representatives must never fabricate or knowingly misrepresent documents, qualifications, references, financial information, application information or other supporting materials.

10. Use and Protection of Company Property

GP2 property, systems and resources must be used responsibly and primarily for authorised business purposes.

This includes:

• Company accounts and systems;
• Documents and records;
• Equipment and devices;
• Intellectual property;
• Branding and digital assets; and
• Confidential business information.

Representatives must take reasonable steps to protect company property from loss, theft, misuse, unauthorised access or disclosure.

Company resources must not be used for unlawful, fraudulent or unauthorised activities.

11. Social Media and Public Communications

Only individuals authorised by GP2 may make official statements or represent the organisation publicly on behalf of GP2.

When using social media or other public communication channels, representatives must:

• Protect student and stakeholder privacy.
• Avoid sharing confidential information.
• Not misrepresent GP2’s partnerships, approvals, affiliations or services.
• Not publish misleading or deceptive information about GP2 or its activities.
• Clearly distinguish personal views from official GP2 communications where appropriate.

Nothing in this section prevents individuals from exercising lawful rights or expressing personal views in their private capacity, provided they do not improperly represent themselves as speaking on behalf of GP2.

12. Raising Concerns and Reporting Misconduct

Everyone representing GP2 has a responsibility to raise genuine concerns about suspected misconduct, unethical behaviour, fraud, bribery, discrimination, harassment, privacy breaches or other serious violations of this Code.

Concerns should be reported promptly through the appropriate GP2 management or compliance channel.

GP2 aims to handle concerns fairly, respectfully and confidentially where appropriate. Retaliation or adverse treatment against a person who raises a genuine concern in good faith is not acceptable.

13. Compliance and Accountability

Compliance with this Code is an important part of representing GP2.

A breach of this Code may result in appropriate corrective or disciplinary action, depending on the circumstances and applicable contractual or employment arrangements. This may include:

• Additional guidance or training;
• Corrective action;
• Restriction or removal of system or business access;
• Termination of employment, contract or partnership; or
• Referral to a relevant regulator, law-enforcement agency or other authority where appropriate or legally required.

The response to any alleged breach will take into account the nature, seriousness and circumstances of the matter.

14. Commitment to Professional Integrity

Every person representing Global Pathway Partners contributes to the trust placed in GP2 by students, families, education providers and business partners.

By following this Code of Conduct, we help maintain a culture built on integrity, respect, transparency, accountability and responsible professional conduct.

All GP2 representatives are expected to use sound judgement, act honestly and seek appropriate guidance whenever they are uncertain about the right course of action.