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TESDA CIRCULAR

Subject: Guidelines in the Implementation of


Dual Training System (DTS) Programs and
Dualized Training Programs (DTP)
umber !!!"#!!!s$ %&#%
Page # of ## Pages
Date Issued:
'ctober #() %&#%
*ffecti+ity:
,s indicated
Supersedes:
In the interest of the service and in pursuit of the agencys efforts to further strengthen and expand the
enterprise-based training programs, including the Dual Training System (DTS) rogram and Duali!ed Training
rograms, the follo"ing implementing guidelines are hereby issued#
I$ G**-,. G/ID*.I*S
The DTS rograms and Duali!ed Training rograms shall be implemented pursuant to the provisions of the
follo"ing la"s#

$% Section & of 'ule (I of 'epublic )ct *o% ++,-, other"ise .no"n as the Technical /ducation and S.ills
Development )ct of $,,&, "hich states that 0T/SD) shall implement 'epublic )ct% *o% +-1-,
other"ise .no"n as the Dual Training System (DTS) )ct of $,,&2, and lend support and encourage
increasing utili!ation of the Dual Training System as provided for in the aforementioned )ct%
3% 'epublic )ct *o% +-1-, other"ise .no"n as the Dual Training System (DTS) )ct of $,,&%
II$ 'bjecti+es
The ob4ectives of the Dual Training System )ct are#
a) To encourage increasing utili!ation of the DTS by both public and private T(Is5
b) To encourage increasing levels of investment in T(/T by both public and private sectors especially in
the rural areas5
c) To enhance the employability and productivity of T(/T graduates by e6uipping them "ith cognitive,
psychomotor, and affective s.ills that are demanded at the "or.place5 and
d) To strengthen cooperation in human resource development bet"een establishments and T(Is by
designing and implementing mar.et-led T(/T programs in coordination "ith the 7ocal 8overnment
9nits (789s) concerned%
III$ Definition of Terms
The terms as used in this :ircular shall mean as follo"s#
a) )ccredited T(/T Institution (T(I) ; a public or private institution duly recogni!ed and authori!ed by
T/SD) to implement the DTS rogram<Duali!ed Training rogram (DT) together "ith a partner
establishment%
b) )ccredited /stablishment ; a private firm duly recogni!ed and authori!ed by T/SD) to implement the
DTS rogram<DT together "ith a partner T(I%
c) =loc. 'elease Scheme ; refers to the schedule "herein the student<trainee spends full time in the T(I to
finish the forty (&>?) percent of the training and then deployed full time in the establishment to
complete the sixty (->?) percent in-plant training%
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TESDA CIRCULAR
Subject: Guidelines in the Implementation of
Dual Training System (DTS) Programs and
Dualized Training Programs (DTP)
umber !!!"#!!! s$ %&#%
Page % of ## Pages
Date Issued:
'ctober #() %&#%
*ffecti+ity:
,s indicated
Supersedes:
d) :ertificate of DTS<DT )ccreditation ; a document issued by T/SD) granting an authority to a T(I and
its partner establishment to implement the DTS rogram<DT%
e) :ontainment olicy ; refers to the policy that does not allo" a T(I to partner "ith establishments outside
their area of 4urisdiction%
f) Daily allo"ance ; refers to the amount "hich the trainee receives from the T(I to defray part of his<her
daily expenses% This amount in no "ay shall be belo" thirty (@>) percent of the trainees allo"ance that
the establishment pays directly to the accredited T(I%
g) Day 'elease Scheme ; refers to the schedule "here the student<trainee spends t"o (3) days "ee.ly in
the school and the remaining "or.ing days of the "ee. in the establishment%
h) DTS )ccreditation ; the granting of 6ualified and approved status to a T(I and its partner establishment
to implement the DTS rogram that meets all the re6uirements of the DTS 7a", particularly on the
prescribed payment of the training allo"ance to the student<trainee%
i) DT )ccreditation ; the granting of 6ualified and approved status to a T(I and its partner establishment
to implement the Duali!ed Training rogram (DT) that meets all the re6uirements provided for under
the DTS 7a", except for the prescribed payment of the training allo"ance to the student<trainee%

4) DTS rogram ; a T(/T program that combines in-plant and in-school training based on a training plan
collaboratively designed and implemented by a T(I and its partner establishment that have DTS
)ccreditation% The duration of the in-school and in-plant training under this system shall not be more
than the duration of the registered program of the T(I% The program meets all the re6uirements
provided for under the DTS 7a", particularly on the prescribed payment of the training allo"ance to the
student<trainee%

.) Duali!ed Training rogram (DT) - a T(/T program that combines in-plant and in-school training based
on a training plan collaboratively designed and implemented by a T(I and its partner establishment that
have DTS )ccreditation% The duration of the in-school and in-plant training under this system shall not
be more than the duration of the registered program of the T(I% The program meets all the re6uirements
provided for under the DTS 7a", except for the prescribed payment of the training allo"ance to the
student<trainee%

l) Dual Training System (DTS) ; an instructional delivery system of technical, vocational education and
training that combines in-plant and in-school training based on a training plan collaboratively designed
and implemented by an accredited dual system educational institution<training center and accredited
dual system participating establishments% The duration of the in-school and in-plant training under this
system shall not be more than the duration of the registered program of the T(I%
m) /stablishment ; refers to enterprises and<or services of agricultural, industrial or business
establishments%
n) In-plant Training ; the portion of a DTS rogram<DT "here student<trainee receives practical learning
by being integrated in the regular "or. system of an establishment%
o) In-school Training ; the portion of a DTS rogram<DT "here student<trainee receives technology-
based theoretical instruction in a lecture area and hands-on exercises in a laboratory and<or a "or.shop
"ithin the premises of a T(I%
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TESDA CIRCULAR
Subject: Guidelines in the Implementation of
Dual Training System (DTS) Programs and
Dualized Training Programs (DTP)
umber !!!"#!!!s$ %&#%
Page " of ## Pages
Date Issued:
'ctober #() %&#%
*ffecti+ity:
,s indicated
Supersedes:
p) Student<trainee ; a person "ho is 6ualified to participate, in order to obtain employable and certifiable
6ualification, in a DTS rogram<DT%
r) Technical-(ocational /ducation and Training (T(/T) ; a comprehensive term that includes all
educational and training processes concerned "ith the study of technologies and related sciences and
directed to"ard the ac6uisition of occupational competencies that are essential for gainful participation
in economic and social activities%
s) Technical (ocational Institution (T(I) ; a private or public school, training center, enterprise-based
training center, and other learning facilities, "hich devote resources under the DTS rogram<DT to in-
school training%
t) Training lan ; a synchroni!ed schedule of .no"ledge and s.ills to be learned by the student<trainee in
the T(I and the actual "or. exercises in the establishment% This can utili!e either the bloc. release
scheme or the day release scheme%
u) Training )llo"ance ; refers to the DTS accredited establishments contribution for training expenses
paid directly to the T(I% It shall, in no "ay, start belo" seventy-five percent (+A?) of the applicable
minimum daily "age for the number of days actually spent by the student<trainee in the establishment for
in-plant training%
I0$ 1o+erage
These guidelines shall apply to all T(Is and their partner establishments duly accredited by T/SD) to
implement the DTS rogram<DT%
0$ General Pro+isions on DTS ,ccreditation
$% The main purpose of accreditation is to ensure high 6uality T(/T by establishing and maintaining the
DTS<DT accreditation standards "hich shall#
a) /ncourage an increasing number of T(Is and establishments to implement DTS rogram<DT5
b) /nsure that the ob4ectives of the DTS la" are achieved5 and
c) /nsure that the management of the DTS rogram<DT is 6uality assured%
3% There shall be t"o types of accreditation, namely# DTS )ccreditation and DT )ccreditation%

DTS )ccreditation shall be issued to T(Is and establishments that meet all the re6uirements provided
for under the DTS 7a", particularly on the prescribed payment of the training allo"ance to the
student<trainee%

DT )ccreditation, on the other hand, shall be issued to T(Is and establishments that meet all the
re6uirements of the DTS 7a", except for the prescribed payment of the training allo"ance to the
student<trainee%
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TESDA CIRCULAR
Subject: Guidelines in the Implementation of
Dual Training System (DTS) Programs and
Dualized Training Programs (DTP)
umber !!!"#!!!s$ %&#%
Page 2 of ## Pages
Date Issued:
'ctober #() %&#%
*ffecti+ity:
,s indicated
Supersedes:
0I$ ,ccreditation Procedures
$% )ll T(Is "ith registered programs are 6ualified to apply for DTS<DT accreditation%
3% The T(I together "ith the partner establishment applies for DTS<DT accreditation in the nearest T/SD)
rovincial<District Bffice (B<DB)%
@% The T(I and the establishment submit the follo"ing documents to T/SD) B<DB#

- )pplication 7etter of the T(I (DTS Corm $)) and the /stablishment (DTS Corm $=)
- )ccomplished )pplication Corm for T(I (DTS Corm 3)) and for the /stablishment (DTS Corm 3=)
- Designation of Industrial :oordinator by the T(I (DTS Corm @)
- Designation of Training :oordinator by the /stablishment (DTS Corm &)
- hotocopy of the T(Is :ertificate of rogram 'egistration (:o')
- hotocopy of the establishments S/: 'egistration
- Demorandum of )greement (DB)) bet"een the T(I and /stablishment
- Training lan (DTS Corm A)
&% T/SD) B<DB verifies the completeness and authenticity of submitted documents%
A% =ased on the evaluation results, the T/SD) B<DB recommends to the T/SD) 'B the grant of the
accreditation to the applicant T(I and establishment "hether DTS )ccreditation or DT )ccreditation%
-% T/SD) 'B issues the corresponding :ertificate of )ccreditation ()nnex :) to the T(I and
/stablishment "hether DTS )ccreditation or DT )ccreditation, through the T/SD) B<DB%
+% T/SD) 'B submits list of ne"ly accredited T(Is and /stablishments to TSDB every fifth (A
th
) day of the
succeeding month%
0II$ 3emorandum of ,greement (3',)

$% The DB) bet"een the T(I and the /stablishment shall set forth, among others, the follo"ing#
a) *ature and ob4ective<s of training5
b) :ommencement and duration of training5
c) Bbligations of the parties concerned5
d) *ormal daily training hours5
e) Insurance coverage of the student<trainee5
f) Cor DTS )ccredited T(I and establishment, the prescribed student<trainees training allo"ance
and the rate to be applied5
g) Cor DT )ccredited T(I and establishment, the student<trainees training allo"ance "hich can
be paid in cash or in .ind (e%g% free meals, free transportation, free board and lodging, free uniform,
etc%)
h) Status of student<trainee5
i) :onditions for the termination of training agreement5 and
4) erformance, monitoring and evaluation system%
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TESDA CIRCULAR
Subject: Guidelines in the Implementation of
Dual Training System (DTS) Programs and
Dualized Training Programs (DTP)
umber !!!"#!!!s$ %&#%
Page 4 of ## Pages
Date Issued:
'ctober #() %&#%
*ffecti+ity:
,s indicated
Supersedes:
3% Signed copies of the DB) shall be provided to the establishment, T(I and the student<trainee or
parent<guardian%
0III$ 5unctions of the Industrial 1oordinator and Training 1oordinator
$% To ensure the effective implementation of the DTS rogram<DT, the T(I and its partner establishment
are re6uired to designate an Industrial :oordinator (I:) and Training :oordinator (T:), respectively%
3% The Industrial :oordinator of the T(I shall perform the follo"ing#
a) lace the student<trainee in the partner establishment for the in-plant training5
b) Donitor attendance, performance and behavior of student<trainee5
c) /nsure the synchroni!ed implementation of the in-school and in-plant training, as reflected in the
Training lan5
d) rovide advice to the student<trainee, trainers<training coordinators, teachers, staff and other
sta.eholders5
Inform immediately the head of the T(I and the establishment of any matter affecting DTS
rogram<DT implementation, "hether positive or negative5
f% /nsure that the provisions of the DB) are being follo"ed5
g% In the event that an establishment has become unconducive for in-plant training in spite of the
issuance of the necessary reminders<notices by the T(I, the Industrial :oordinator shall
recommend to the Eead of the T(I the termination of the partnership and effect the transfer of the
affected student<trainee to another partner establishment%
@% The Training :oordinator of the establishment, on the other hand, shall perform the follo"ing#
a) 'esponsible for the planning, organi!ing, implementing, evaluating and coordinating the in-plant
offered to DTS<DT student<trainee5
b) Donitor the performance and behavior of the student<trainee and ma.e recommendations
concerning discipline5
c) /stablish a regular communication<coordination and feedbac. mechanism "ith the Industrial
:oordinator5 and
d) Deet "ith the representative of the partner T(Is in the implementation of the DTS rogram<DT%
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TESDA CIRCULAR
Subject: Guidelines in the Implementation of
Dual Training System (DTS) Programs and
Dualized Training Programs (DTP)
umber !!!"#!!!s$ %&#%
Page 6 of ## Pages
Date Issued:
'ctober #() %&#%
*ffecti+ity:
,s indicated
Supersedes:
I7$ 'bligations of the ,ccredited Technical 0ocational Institution
$% The accredited T(I shall perform the follo"ing#
a) Fointly "ith the partner establishment design, implement, and evaluate the Training lan5
b) rovide specific, general, and technology-related theoretical instruction and basic practical
training5
c) )ppoint Industrial :oordinator<s to supervise the in-plant training5 and
d) erform such other duties and tas.s as may be necessary to reali!e the ob4ectives of the DTS
program%
3% The accredited T(I shall ensure that the provisions of the DB) are properly implemented and coordinated
"ith the partner establishment for the purpose of ensuring high standards of training under the DTS
rogram<DT%
@% The accredited T(I shall ensure that the graduates of DTS rogram<DT undergo competency
assessment after their training%
&% The accredited T(I shall issue a :ertificate of Training to DTS rogram<DT student<trainee upon
completion of the training%
7$ 'bligations of the Student8trainee
$% Cor the duration of the DTS rogram<DT, the student<trainee is not to be considered employee of the
accredited establishment%
3% The student<trainee shall exert every effort to ac6uire the abilities, values and .no"ledge necessary to
achieve the purpose of training% To"ards this end, the student<trainee shall#
a) erform carefully the tas.s entrusted to him<her as part of the training by the Trainer<Training
:oordinator or any other person authori!ed to give them instructions5
b) Bbserve rules of behavior in the company premises particularly at the in-plant training area5
c) 9se tools, instruments, machines and other e6uipment "ith due care5
d) *ot reveal any business nor trade secrets that have come to their .no"ledge in the course of their
training5
e) Geep up-to-date their in-plant training log boo.s, diaries, or their e6uivalent5 and
f) 'ecord their daily attendance both in-school and in-plant%
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TESDA CIRCULAR

Subject: Guidelines in the Implementation of
Dual Training System (DTS) Programs and
Dualized Training Programs (DTP)
umber !!!"#!!!s$ %&#%
Page 9 of ## Pages
Date Issued:
'ctober #() %&#%
*ffecti+ity:
,s indicated
Supersedes:
7I$ 'bligations of ,ccredited *stablishment
$% The accredited establishment shall perform the follo"ing#
a) Fointly "ith the accredited T(I, design, implement and evaluate the Training lan5
b) /nsure the provision of a systematic training, in accordance "ith the approved Training lan, to
the student<trainee in order for him<her to achieve the purpose of the training5
c) )ppoint a Training :oordinator and trainers to implement the Training lan5
d) Da.e available to student<trainee the consumable materials, basic hand tools and e6uipment that
are necessary for training, free of charge5
e) )llo" the student<trainee to attend the in-school training and to sit for their examinations5 and
f) 'e6uire the student<trainee to .eep up-to-date the logboo.s, diaries, or their e6uivalent5
g) Inspect regularly such logboo.s, diaries, or their e6uivalent5
h) /nsure that the student<trainee is encouraged to develop his<her personality and that he<she is
protected from physical and moral danger5
i) /ntrust to the student<trainee such 4obs as are related to the purpose of their training and are
commensurate "ith their capabilities5
4) Cor the establishment "ith DTS )ccreditation, pay the prescribed training allo"ance of their
student<trainee through their partner T(I5
.) Cor the establishment "ith DT )ccreditation, pay the training allo"ance of their student<trainee
through their partner T(I in cash or in .ind%
l) )llo" the student<trainee to go on vacation during periods specified in the DB)5 and
m) The accredited establishment shall issue a :ertificate of Training to the student<trainee upon
completion of the in-plant training%
3% The accredited establishment shall inform in advance the union<"or.ers group in the said
establishment prior to accepting students<trainees%
@% The accredited establishment shall ensure that accident insurance coverage is provided for each
student<trainee%
&% The accredited establishment is encouraged to give preference to the DTS rogram<DT graduates in
the hiring of "or.ers%
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TESDA CIRCULAR
Subject: Guidelines in the Implementation of
Dual Training System (DTS) Programs and
Dualized Training Programs (DTP)
umber !!!"#!!!s$ %&#%
Page ( of ## Pages
Date Issued:
'ctober #() %&#%
*ffecti+ity:
,s indicated
Supersedes:
7II$ *TIT.*3*TS ,D P-'1*D/-*S I T:* ,0,I.3*T '5 I1*TI0*S ;< T0Is ,D
*ST,;.IS:3*TS =IT: DTS ,11-*DIT,TI'
$% 'evenue 'egulations *o% $>-,- of '%) +-1- provides tax incentives to accredited T(I and
establishment% % Bnly the T(I and partner establishment "hich have complied "ith the provisions of the
DTS 7a" and granted DTS )ccreditation are entitled to avail of the incentives% 9nder Section @ thereof,
a DTS accredited establishment is entitled to avail of the follo"ing tax incentives#
a) Deduction from their taxable income the amount of fifty percent (A>?) of the actual system
expenses paid to the )ccredited Dual Training System /ducational Institution for the
establishment trainees5 rovided, That, such expenses shall not exceed five percent (A?) of
their total direct labor expenses but in no case to exceed t"enty five million pesos
(hp3A,>>>,>>>% >>) a year%
b) Donation, contribution, be6uest, subsidy, or financial aid actually paid or made 5'- T:*
'P*-,TI' '5 T:* S<ST*3 "ithin the taxable year shall also be deductible for income tax
purposes in an amount not in excess of three percent (@?) of the taxable business income of the
establishment computed "ithout the benefit of deduction% Eo"ever, if the Dual Training System
/ducational rogram is included in the list of *ational riority rograms (*), as determined by
the *ational /conomic Development )uthority (*/D)), then corporate contributions to the System
shall be deductible in full from its taxable business income for the taxable period "hen actually
made, sub4ect to the conditions imposed under =I'-*/D) 'egulations *o% $-1$, as amended,
implementing Section 3,(h) of the *I':, as amended by =atas ambansa =lg% &A5 and
c) /xemption from Donors tax, provided, ho"ever, that not more than thirty percent (@>?) of said
gifts shall be used by the System for the administration purposes pursuant to Section ,&(a) of the
*I':, as amended%
3% Section & of the said I'' also provides that an accredited T(I is entitled to avail of the tax incentives% It
states that 0/ssential e6uipment, apparatus and materials imported by accredited dual training
educational institutions shall be exempt from taxes (i%e% (alue-)dded Tax (()T), ad valorem, or excise
tax) and duties# rovided, that, the importation of these items shall be sub4ect to certain 6ualifications
as provided for under Section A (II) hereof%2
@% The follo"ing procedures shall be observed in the availment of tax incentives#
I$ ;y establishments >ith DTS ,ccreditation - in order to avail of the tax exemption and
incentives, the accredited establishment shall file and submit to the 'evenue District Bffice ('DB)
of his principal place of business the follo"ing documents to support and substantiate his claim%

Cor exemption from donors tax and as allo"able deductible expenses from taxable income for
income tax purposes, Section A of the I'' provides that the establishment shall submit the
follo"ing#5
$% ) letter of application duly signed by the appropriate authority of the concerned agricultural,
industrial or business establishment participating in the Dual Training System5
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TESDA CIRCULAR
Subject: Guidelines in the Implementation of
Dual Training System (DTS) Programs and
Dualized Training Programs (DTP)
umber !!!"#!!!s$ %&#%
Page ? of ## Pages
Date Issued:
'ctober #() %&#%
*ffecti+ity:
,s indicated
Supersedes:
3% Demorandum of )greement duly executed<signed by the accredited dual training system
agricultural, industrial or business establishment, the accredited dual training system
educational institution<training center and the trainees5
@% )ccreditation of the Dual Training /ducational Institution by the appropriate authority5
&% )ffidavit or statement under oath by the participating educational institutions as to the actual
amount received for the establishments trainee<s, on an annual basis5 and the corresponding
official receipts ac.no"ledging the contributions<donations made by the participating
establishment5
A% )ffidavit or statement under oath by the participating establishments as to the actual amount
donated<contributed to the )ccredited Dual Training System /ducational Institutions for the
operation of the Dual Training system, on an annual basis, and the corresponding official
receipts issued by the participating educational institutions5
-% Cinancial statement of the participating establishment for the year "hen the tax
exemption<incentive is being claimed5
+% S/:<DTI 'egistration :ertificate<s of the participating establishment5 and
1% )rticles of Incorporation and =y-7a"s, or other documents sho"ing the nature of business of
the concerned establishment%
II$ ;y T0Is >ith DTS ,ccreditation @ In order that the essential eAuipment) apparatus and
material imported by the participating educational institutions may be eBempt from taBes (i$e
0,T) ad +alorem or eBercise taBes)) the follo>ing reAuirements should be complied >ith:
$) )pplication for exemption shall be filed "ith the 'evenue Bffice, Department of Cinance,
Danila, duly signed by the Eead of accredited dual training educational institution or his
authori!ed representative, together "ith the follo"ing documents#
a) =ill of lading, air"ay bill, parcel post<notice and other shipping documents
b) :ommercial invoice and pac.ing list5 and
c) Bther relevant documents concerning the shipment%
3) :ertification from T/SD) that the importer is an accredited dual training educational
institution, together "ith a recommendation that the importation<s is<are necessary in
connection "ith the dual training system5
@) )ffidavit<Statement under oath executed by the applicant stating, among others, that the
imported articles are essential and "ill be used actually, directly and exclusively in connection
"ith the dual training system5
&) :opy of the :harter or :ertificate of 'egistration of the educational institution "ith the S/: or
other evidence of the character of the institution5
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TESDA CIRCULAR
10
Subject: Guidelines in the Implementation of
Dual Training System (DTS) Programs and
Dualized Training Programs (DTP)
umber !!!"#!!!s$ %&#%
Page #& of ## Pages
Date Issued:
'ctober #() %&#%
*ffecti+ity:
,s indicated
Supersedes:
A) :ertification from the Department of Trade and Industry or appropriate government agency
that the articles to be imported are not available locally in sufficient 6uantity and of
comparable 6uality at reasonable prices5 and
-) )ffidavit or statement under oath that the imported articles, "hich shall be mar.ed and posted
0T,7 ,D D/T< 5-** /D*- -$,$ '$ 96(6C in a conspicuous place as the nature of the
importation "ill permit, "ill not be sold, transferred or other"ise disposed of any manner "ith
the prior approval of the Department of Cinance%
7III$ P'ST ,11-*DIT,TI' 1'1*-S
$% The accredited T(I shall submit to the T/SD) B<DB Training</mployment 'eport (DIS >@->3)
and other re6uired information<documents "ithin ten ($>) "or.ing days upon start of the program
and an updated copy of the report for Training :ompleted (a,l) and /mployment (ao, ap, and a6)
every $A
th
day of the month%
3% The T/SD) 'B shall submit the Training</mployment 'eport (DIS >@->3) to the :orporate
)ffairs Bffice (:)B) every 3A
th
day of the month%
@% )ll T(Is and establishments that "ere accredited by T/SD) prior to the effectivity of these
guidelines shall be issued their ne" :ertificate of DTS )ccreditation or :ertificate of DT
)ccreditation by the T/SD) 'egional Bffice%
&% )nnual revie" of compliance by the T(I and its partner establishment "ith the foregoing shall be
underta.en by T/SD) B<DB% Such revie" shall be made part of the compliance audit conducted
by T/SD) B<DB%
A% TSDB shall prepare a consolidated list of accredited T(Is and establishments and facilitate its
uploading in the T/SD) "ebsite%
7I0$ -*0'1,TI' '5 ,11-*DIT,TI'

The follo"ing are the grounds for the revocation of the 4oint accreditation of the T(I and its partner
establishment#
$% *on-compliance of the T(I and<or the establishment on the approved training duration of the DTS
rogram<DT5
3% Cor the establishment "ith DTS )ccreditation, failure to pay the prescribed training allo"ance of
the student<trainee to the T(I5
@% Cor the T(I "ith DTS )ccreditation, failure to pay the prescribed training allo"ance of the
student<trainee paid through them by the establishment5
&% Discovery of any fraud or deceit in connection "ith their application for DTS<DT accreditation5
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H(%
H(I$
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