If it is as described, you know the industry is well on the road to perdition, when charter companies have to fund their bottom line with such shenanigans.
It is immoral, UnChristian, uncharitable, etc. etc, blah, blah, and the sort of scam regularly exposed on ACA, Springer et al.
Bit like the, "you should be a model, for $3,000 I'll do a photo portfolio for you that'll get you onto the worlds catwalks"
And yep the "least likely to" fall for it almost everytime.
Unfortunately it's not big enough to grab public attention, but it might be something that Consumer Affairs or Fair Trading might find interesting.
I have absolutely no probs advertising ratings on a pays your money you take your chances.
However, cycling new graduates through the RHS does not sound like the sort of work practise that would get my tick for "professional duty of care".