VXL Employee Code of Conduct 

Aligned with MARA, internal policies, and client trust. 

1. Purpose and Scope

This Code defines expected standards of professional, ethical, and lawful behavior for all VXL employees, agents, and contractors. It ensures compliance with: 

• The MARA Code of Conduct (effective 1 March 2022) 

• Australian Privacy Principles and relevant global data laws (GDPR, CCPA, etc.) 

• VXL’s internal policies, terms, and client promises 

2. Professional and Ethical Conduct

• Act honestly, fairly, and with integrity at all times. 

• Provide accurate, non-misleading advice and never guarantee visa or admission outcomes. 

• Avoid conflicts of interest, disclosing and managing any unavoidable cases immediately. 

• Never misuse your access to client information, documents, or communication tools. 

3. Legal and Regulatory Compliance

• Abide by migration law and MARA Code of Conduct obligations. Never attempt to circumvent the law. 

• Do not provide immigration advice unless authorized and registered. 

• Ensure communications (email, WhatsApp, SMS) with clients are professional, respectful, and clearly documented. 

4. Client Interaction Standards

• Always act in the best interests of the client, maintaining professionalism during inquiries, bookings, and follow-ups. 

• Use clear language in written or verbal communication. 

• Ensure clients understand all fees, scopes of service, and expected timelines before accepting payments. 

5. Privacy, Data Protection & Confidentiality

Handle personal data (e.g., identity, visa, education, financial info) confidentially and securely. 

Follow VXL’s internal retention schedule: 

• Inquiries: retained 24 months after last interaction. 

• Clients: 7 years post-case closure. 

Limit access to client data only to those with a clear role-based need. 

Respect client rights: access, rectification, deletion, and objection, as per applicable data laws. 

6. Technology, Website & Cookies

Follow secure practices when handling devices, portals, or customer info via the website or third-party tools. 

Do not bypass or tamper with cookie and analytics tracking without cause. 

Respect limitations and responsibilities detailed on VXL’s public platforms, including avoiding misrepresentation through external tools (e.g., WhatsApp, Student Portal). 

7. Transparency, Recordkeeping, and Communication

Ensure accurate records of client interactions and advice are maintained. 

Do not alter, withhold, or destroy information that may be needed for audits, legal compliance, or complaint investigations. 

Keep MARA and internal supervisors informed of any client complaints or compliance risks. 

8. Use of Company Identity & Intellectual Property

Use VXL’s logos, content, and platforms responsibly and only with permission. 

Do not claim representation for the company in public or online platforms without prior approval. 

9. Training & Supervision

Attend required MARA CPD training and internal workshops on data protection, client service, and legal compliance. 

Supervisors are responsible for ensuring junior staff understand this Code. 

10. Reporting Violations and Sanctions

Employees must report suspected violations of this Code or MARA Code of Conduct to their line manager or compliance lead. 

Violations may lead to disciplinary action including termination and, if relevant, notification to MARA. 

11. Signature and Acknowledgement

Each employee must sign below acknowledging receipt, understanding, and commitment to comply with this Code of Conduct.