Fran Hall

Today’s offering from a person who wrote to the FSCSR in response to the invitation for unaffiliated funeral directors to contact the independent chair was sent by us on their behalf.

The author chose not to identify themselves in the letter because it had to be sent to the independent chair via the FSCSR Secretariat, which is run by the trade associations that this individual has elected not to belong to.

It struck the writer that this meant their letter would potentially be read by others, and they preferred that their name and location not be identified in such a way.

Obviously we know who the author is, but we are preserving their anonymity in publishing their letter without attribution.

(Postscript – the independent chair of the FSCSR has subsequently been in direct contact with the author and assured them of his independence.)


Dear Mr Shand-Smith

Re: Call to non-trade association affiliated funeral directors to share their views

I write to you in your capacity as Chair of the Funeral Service Consumer Standards Review to explain who I am and why I no longer belong to the NAFD, and also to highlight some of the failings within the Trade Associations.

I would also say that this call to us to respond is incredibly short notice and unlikely to be a great success given the time of year. I hope sincerely that that wasn’t your intention.

I am an independent funeral director who started up from scratch 11 years ago. I had only briefly worked in the funeral profession prior to opening, our facilities were very basic and we relied on a friend (and business partner) for help with staff, logistics and vehicles.

We did not join a Trade Association for a couple of years but we (myself and my wife) studied the Dip. FAA with the NAFD as soon as we started. As time went on we decided to give our business the added credibility of membership to the trade organisations SAIF and the NAFD. We are no longer members of the NAFD, reasons for which I shall outline later, but it was our decision. We are members of The Good Funeral Guide though, a consumer guide to good funeral practice.

We knew what we needed to do to succeed, and how to do it, and tighter regulation may have prevented us from opening but would that have been a good thing? We are now as big a business in our area as all the other firms and carry out as many, if not more funerals a year as anyone else in our area, because we fulfil a need and we do it well.

It is my belief that new businesses do not start up to rip off the unsuspecting consumer but because they have identified that consumers are currently being ripped off and they can offer a better service! This may not strictly be true in all cases but a lot of new businesses start up because the old family-run firm has been taken over and things are no longer done in the way they were, much to the embarrassment of the staff and disappointment of the customers.

In a report by Beyond.Life into Dignity Funeral Services and their share price they show that, and I quote:

“Between 2005 and 2016 (“the historical period”) the Company delivered:

Revenue growth from £143 to £314 million (7.4% cagr)

Operating profit growth from £42 to £98 million (8.1% cagr)

EPS growth from 22.4p to 119.8p (cagr 16.5%)

There have been two drivers of this historical performance:

a 53% increase in the number of branches (3.9% cagr); and

an 81% increase in pricing (6% cagr)

Branch expansion has mainly functioned to keep customers steady and offset a collapse in branch productivity

Dignity’s market share has been static at c.12% with customer numbers ranging from 62,300 to 73,500 as a function this static market share and a variable UK death rate

Branch productivity, in terms of funerals performed per location per year, has collapsed by more than 30% from 129/year in 2005 to 87/year at H1 2017.

Acquired locations typically provide around 150 funerals per year initially, offsetting customer losses elsewhere in the portfolio.

Pricing has been used to provide constant top-line growth

With customer numbers flat over the historical period, pricing has been used as a lever to provide revenue growth

Prices increased every year between 2005 and H1 2017 from £1,699 to £3,153 at a cagr of 5.6%, in line with the growth within the Funeral Services segment cagr of 6.1%

Effectively, management have driven top line growth through large price increases across the existing portfolio, whilst offsetting decreasing customer numbers in the existing portfolio by acquiring new locations. The net result is that Dignity serves roughly the same number of customers each year but charges each of them a higher price.” The full report is available here.

This, I believe is why new start-up businesses come about, and tighter regulation may prevent them from doing so, holding the public to ransom with high charges and lower standards offered by the big chains.

As an example of this, when our local branch of Dignity was taken over in 2006 they were carrying out the vast majority of funerals in the area (circa 600 per year), now they carry out about 250. You need to be asking why!

The Co-op has never really featured locally and Funeral Partners are not in the area so Dignity is our only point of reference for this.

It is my opinion that any investigation into the funeral profession should be aimed primarily at the big groups of funeral directors, to understand why they have lost half of their customers in the years after purchasing the business, why their charges are consistently higher than that of independents, despite them having all the economies of scale that the independents do not, and why they have a high turnover of staff, certainly a feature in our area, and I would plead with you not to let this whole investigation be led by the one group of people that need to be investigated but by proper, independent consumers.

Let it be led by those who may need our services, not by those who provide them. Would you let a second-hand car industry investigation be led by second hand car dealers? The trade associations exist purely to protect the interests of their members, NOT THE GENERAL PUBLIC.

There have also been TV programmes into malpractice in the funeral profession. Dispatches, on Channel 4 in 2012 uncovered various horror stories at the Co-op, as did the ITV report The British Way of Death with Funeral Partners. I’m sure that there are some unscrupulous independent funeral directors too but stories in the media would suggest that there are more complaints with the bigger firms.

After joining the NAFD I attended several of the local branch meetings but half of the room was filled with Co-op and Dignity members and no one seemed keen on bringing them to account for their high prices or shoddy practices. Their chief concern seemed to be who was next in line to receive the Chain of Office and who was buying the drinks!

On Radio 4 one Sunday in December 2018 there was an interview/ discussion about funeral costs featuring Abi Pattenden, then President of the NAFD and Louise Winter, a new and progressive funeral director in London.  Ms Pattenden’s arguments for defending the costs charged by some of her member firms were shocking and she was thoroughly shot down by Ms Winter on all counts. She was poorly prepared and, maybe because she actually works for an independent firm, didn’t really believe what she was saying. It was for this reason that I decided that the NAFD no longer represented my views. A belief I still hold.

In summary, I ask you to take a long hard look at our profession, but from the outside. There is absolutely no point in asking the membership of the largest trade organisations what they would like to see, when they obviously want to defend their members.

This needs to start from the other end, what do consumers want, where are they most likely to get that. Look at’s price comparison website, it’s not that great and I’ve had my disagreements with them but you can see a guide to funeral costs there. Ask probing questions to leaders of big companies and small. FIND THE TRUTH.

I do hope that you can take my points seriously and consider the view from the other side of the arrangements table. Please do feel free to contact me if I can be of any further assistance.

With kind regards

Fran Hall

It seems that there are people in positions of some authority in funeralworld who don’t quite understand the Good Funeral Guide’s position on the idea of regulation of the funeral industry.

This is strange, because we thought we had made ourselves quite clear over the years.

We have written about it many, many times – type ‘regulation’ into the search bar on the blog and more than 50 results pop up.

The very first blog post on the subject was written by Charles back in 2009, a powerful piece arguing in his usual articulate fashion that “Lousy undertakers can never be improved by training courses and government regulation.”

He goes on to state: “Professionalising and regulating undertakers can only reinforce the perception that they are the default disposers of the dead and, worse, move them a step closer to being the only people licensed to do so.

You are the default disposer of your dead. The undertaker, if you choose to engage one, is your agent. That is your ancient right, and that right defines your responsibility both to yourself and to your dead. Let us honour all those superb undertakers out there who embrace that.”

While this continues to be our absolute and certain belief, over the last ten years since Charles wrote that excellent post, it has become apparent that some form of regulation of the funeral sector is likely to be inevitable.

Huge efforts are underway by powerful players in the funeral industry to shape the form of regulation.

The focus of these efforts appear to be on “Quality and Standards’ – interestingly two words that Dignity are concentrating on, see the report published by Dignity PLC  in August 2018 “Time to Talk About Quality and Standards”. We wrote about the report here and the full document can be downloaded here.

Our position on the prospect of regulation of the funeral sector (as laid out very clearly in a blog post on 26th September 2018) is as follows.

In bold, so that those reading the blog don’t miss it again:

At the GFG we have long taken a stance that regulation of the funeral industry needs to be carefully considered and crafted, and definitely not determined by the trade associations involved. Trade associations are exactly what the name implies.

Any decision on regulation should be led by the interests of the bereaved person, a consumer focus that trade associations are, by definition the exact opposite to. Trade associations represent the interests of their members. Full stop.

Hope this clears up any misunderstanding (or any manoeuvres to portray the GFG as being completely against any kind of regulation).


Now we have to dash. It’s a busy week.

Fran Hall

As today’s meeting of the Funeral Service Consumer Standards Review Working Group B (the Transparency Working Group) gets underway, we are delighted to share the thoughts of another respondent to the invitation to comment issued by the FSCSR on the Friday before the Bank Holiday weekend.

Today’s contribution is from Fran Glover and Carrie Weekes of A Natural Undertaking.

NB: The as yet unpublicised members of the FSCSR Transparency Working Group may wish to consider some of the questions posed below.

Dear Mr Shand Smith

We were hoping to get this email to you by Friday 30th but as a small independent funeral director we have been incredibly busy.

We write in relation to the call for views from non-trade association affiliated funeral directors. We were alerted to this by two of the FSCSR members, Poppy Mardell and Sarah Jones, and whilst we are members of SAIF feel we have some questions about this group that we would like to ask independently.

We are a progressive and passionate funeral director, working hard to provide a high quality and personal service to the people who come to us. We welcome the government review of the funeral industry and the independent perspective that they will bring.

For ease and the sake of brevity we list our questions below:

  • Can you help us understand what this group hopes to achieve that is not already within the remit of the government appointed CMA team, and why it would be doing this work ahead of the CMA timetable for delivery or any recommendations that come out of it? This feels confusing for someone in the industry, let alone a member of the public who may not be quite so familiar with what is currently taking place.
  • We would like to understand how the group plans to deliver an impartial, independent response where most members of the steering group are heavily invested in any remedies which will be prescribed? (Key members being NAFD, SAIF, COOP and Dignity who all manage or deliver a large proportion of funerals currently)
  • We would also like to understand where the legitimacy of this group originates. Our understanding is that this is not a government appointed group, so where does the authority to call itself a consumer review group stem from?
  • Assuming a funeral director expresses interest in taking part, we would like to know what that actually means? Will those funeral directors have a seat at the table to discuss the challenges, or is it merely to ‘review’ and ‘comment’ upon the work that the FSCSR discuss? To what extent would their views be incorporated into any remedies?

We would also like to comment on the timeframe given for this call out – if the request for views is genuine then it would seem that an 8 day period over a bank holiday is way too tight a timeframe for people to hear about it, consider their position and then respond. Our own constraints and workload have meant that we have been unable to reply with a considered response within the stated timeframe.

  • Finally, since this is named as a consumer review group, it would be good to understand how and where the views of the consumer are represented within this group? We understand that consumer bodies will be consulted but surely there should be an independent consumer body on the steering group, working on this from the outset?

The changes that could take place as a result of any work being done in this arena are so important that we hope you therefore understand why we are asking these questions, and we look forward to hearing your responses.

Best wishes

Fran Glover and Carrie Weekes

Fran Hall

Here’s another submission that squeaked in before the deadline set by the self-appointed Funeral Service Consumer Standards Review group to hear the views from funeral directors who choose not to belong to a trade association – from the fabulous Jennifer Uzzell, occasional contributor to the blog and one of the directors of Saint & Forster Funeral Directors Ltd in Darlington:

“Dear Mr Shand-Smith

In response to your request for views from funeral directors who are not affiliated to the trade organisations and who would like to add their views to your consultation, please see below. 

I am one of the directors of Saint and Forster Funeral Directors Ltd. in Darlington in the North East of England. 

The company was set up by my partner Keith Munt and myself 8 years ago

We are not members of a trade organisation as it is our belief that these organisations exist in order to promote the interests of their client businesses and that, where a difference exists, they will promote the interests of their clients above those of the bereaved. They are, therefore, not in a position to represent the interests of the bereaved, or to administrate any form of regulation that may be introduced. 

I note with concern that the FSCSR appears to be presenting itself as the body that represents the funeral service in general and will, in fullness of time, be responsible for regulation. As far as I can see, the FSCSR has no remit or authority to do this, and it seems to a number of us that you are positioning yourself to defend the actions of the larger corporations, even when their performance is very poor; and to regulate against the interests of small independent and unaffiliated companies even where they are ethical. Our failure to join any of the associations is ethically motivated and is in no way because we have anything to hide, or because we do not feel we would meet the criteria.

I also question what your motivation was in allowing such a small window of opportunity for unaffiliated FDs to reply to your request for their views. Either you are deliberately trying to limit the number of responses you receive, or we are very much an afterthought. Neither possibility is particularly encouraging. 

Much that has been presented recently, in terms of the need for regulation, has been about the need to protect the public from ‘cowboy’ ‘unqualified’ practitioners who are setting up businesses across the country. I do not doubt that a small number of such businesses exist. However, as the evidence presented by my colleague Louise Winter (with whom I am in entire agreement, and whose letter to you I attach below in its entirety) suggests, the majority of instances of malpractice or poor quality service seem to be traceable to larger corporations rather than to smaller independent companies. 

You ask specifically for my views on regulation, which I give below. 

I welcome regulation of the funeral service, with the following provisos:

  • Any regulation must be overseen by a body that can be shown to be truly independent. This should not be the trade organisations, the FSCSR, or any other body with a vested interest. 
  • Complaints should be handled by an independent ombudsman as they once were
  • Any system of regulation should not be limited to process (how bodies are stored, transported etc and how FDs are trained; important as these things are) but should also include an ethical element aimed at preventing the exploitation, financial or otherwise, of the bereaved. 
  • FDs should not be required to have a qualification, particularly if it is devised, administered and awarded by the NAFD. This is, again, a vested interest and also, to my knowledge, contains training that would be at odds with my idea of good practice. There is a disturbing movement in the world in general at the moment towards the perception that academic qualification with increasingly low standards are a guarantee of quality. 
  • With regards to the above, I would like to see FDs or businesses licensed according to what they can demonstrate that they can do in a system similar to the old NVQs, rather than requiring them to acquire an additional qualification. Again, this license must be administered by a truly independent body with no vested interests. 

Many companies, such as mine, have been set up by people with entirely adequate facilities. training and experience, but with a new vision of the quality, standards and emotional intelligence that the public should be entitled to expect from us. Any regulation must enable those companies to continue and to thrive and to provide a choice to the public. 

To conclude, I state again that I am entirely in agreement with Louise Winter of Poetic Endings, whose letter I attach in full here.  

Kind Regards, 


Jennifer Uzzell


Office Manager

Saint and Forster Funeral Directors Ltd


Letter to Lewis Shand Smith – 29th August 2019

Fran Hall


Remember these guys?

The National Federation of Funeral Directors – they of the combative Managing Director who regularly took umbrage with Charles – have a look at blog posts from the past here and here and here and here to refresh your memory.

They were the self styled “Consumer Driven Funeral Industry Governing Body committed to “increasing consumer choice and cost transparency within the funeral industry; and to the modernisation, development, and on-going commercial welfare of its funeral director and subsidiary business Members.”

And their mission was to “modernise, develop, enhance, and protect the funeral industry, and to provide consumers with a greater, more informed, choice when faced with the costly and emotional task of arranging a funeral.”

Have a click on this link:

They’ve gone. Vanished. Vamoosed.

The NFFD is no more.

So, if you come across this symbol on a funeral director website then it sadly doesn’t actually mean anything.


We’re trying to work out what’s happened, not least because the NFFD strongly endorsed Safe Hands Funeral Plans – have a look here.

We bet Dr. Hilary Jones is feeling a bit silly now.

Fran Hall


After yesterday’s deadline for unaffiliated funeral directors to make contact with the FSCSR came and went, we thought we would share some of the thoughts from some of the people who managed to scrabble together a response to the request within the time frame offered.

Given that all responses were received by the FSCSR Secretariat, which is operated by the two funeral trade associations, these responses are hardly confidential, and all concerned are happy for their comments to now be in the public domain.

We begin today with the letter sent by Ru Callender, from The Green Funeral Company


My partner and I have been independent self taught undertakers and celebrants for the past twenty years. We run The Green Funeral Company.

We set up as a direct result of the dissatisfactory funerals I was subjected to throughout my childhood and twenties at the hands of the very corporate organisations which appear to be covertly represented here.

I discovered the work of The Natural Death Centre charity, which back then was a radical movement to empower the public and force funeral directors to show a little transparency.

It taught me, as you all know but I doubt much of the public do, that a family are not required by law to use a funeral director. They can do pretty much everything themselves, and we have indeed advised and supported many families to do exactly this, as well as providing a much more integrated and participatory service for the families who do chose us.

The reason this is possible is simple; dead bodies are not complicated, or as much of a health hazard as is generally perceived. You can disrespect them, but you cannot hurt them.

The real skill of funeral directing lies with how you treat the living.

 And no amount of spot checks or being part of a trade body will ensure that the living are treated well. This requires emotional intelligence, which is teachable to a degree, but is unlegislatable.

We believe regulation will destroy some of the best funeral directors in the country while appearing to ‘solve’ a problem in the eyes of the public, that doesn’t actually exist.

The problems that actually exists in the funeral industry are:

An emotional disconnect between individual funeral workers and the families they are serving, mainly in large corporate chains, and a lack of support for these workers when it comes to the complexities of the psychological stresses involved with the job.

A financial beholdenment to shareholders within the corporate sector above all else.

 The overmarketing of funeral plans as a tactic to secure future business by the large corporations forcing smaller funeral directors to follow suit in a manner which brings the moral tone of our work down in the eyes of the public through tasteless emotionally bullying adverts on daytime television.

 And most obviously, our crematoriums are with a few very notable exceptions no longer fit for purpose, environmentally, practically, spiritually or financially.

They have inappropriate outdated designs and short time slots and are mainly worked around the on time traffic of too many funerals per day.

These are the issues which are affecting the quality of funerals in the UK today.

Let me elaborate on my first point, about the emotional labour required to do this job properly.

By disconnect I mean that often with the larger chains, the people who pick up the body are not the same as the person who makes the arrangements, who is not the same as the person officiating on the day.

This lack of continuity reduces the dead person to a logistical problem, storing them in large central warehouses in identical coffins, and takes any emotional and narrative stake away from the people at the sharp end of the job.

They are as much a victim of the lack of joined up thinking as are families.

With no real training in the dynamics of shock, grief and bereavement and the impact these have on funeral workers, you have people on very low wages collecting bodies in the middle of the night walking into people’s houses in the middle of the night to collect their dead father asking “Where is it?” This happened to friends of mine.

We are not members of any trade organisation for many reasons, but largely because trade organisations in any industry largely exist to serve their members, while giving the public a veneer of accountability.

The funeral trade organisation offer cheaper insurance, a few quid off this and that, and are completely obsessed with selling pre paid funeral plans, most of which don’t significantly help the funeral director.

And the majority of the members of the largest trade body, the NAFD, are from the various Co-op’s who dominate the agenda to suit them, and use their enormous clout to produce endless press releases about changing trends in funeral music ignoring the bigger changes that have been created by small radical undertakers like ourselves,

When we make a mistake, as inevitably in the past twenty years we have, the buck stops with us. We are the complaints department as well as everything else. We are accountable, and own our mistakes and rectify them without the need for an intervening trade body. This is simple good and ethical business. People stand and fall on their reputation.

Don’t get me wrong, funeral directing is an extremely hard job, physically, psychologically and emotionally, and if you are doing it and it is not your vocation, then you will burn out.

Obviously we do not accept the widespread cultural belief that funeral directing is somehow exploitative, there are lots of fabulous undertakers, both independent and within some of the larger chains quietly and sincerely giving of themselves, but there are enormous corporate behemoths hiding behind a lot of good will and misunderstandings of the general public, and this regulation will only benefit them, while punishing the cutting edge creativity of many independents.

Forcing regulation on the industry will shut the door on ordinary members of the public participating in their own bereavement experience, and will close down the visionaries of this industry, all for the sake of convincing the public that they are protected, and has been tried by vested interests in the industry for over 100 years, with the same agenda; the shutting down of small independents.

Fran Hall

Eight days ago (three of which were over a bank holiday weekend), funeral directors who don’t belong to either of the funeral trade associations were invited to get in touch with the Funeral Service Consumer Standards Review – the self appointed body founded by Dignity PLC that is looking at ‘quality, standards and outcomes for funeral service consumers’.

The independent chair wrote on the FSCSR website “If you are a member of SAIF or NAFD, then they have a seat at the table to represent your views – but we really want to make sure that non-trade association affiliated funeral directors also have the opportunity to express their thoughts.

So, if you are a funeral director who is not a member of a trade association and would like to contribute your views on how to improve funeral care (or express your specific concerns about current standards, or possible regulation in the industry), then please get in touch with by Friday 30 August.”

This invitation was also tweeted out to the 71 followers of the FSCSR account. 

So, unless non trade association affiliated funeral directors happened upon the FSCSR website (why would they?), or followed the FSCSR Twitter account (followers seem to be organisations, heads of organisations and a smattering of individuals) then non trade association affiliated funeral directors are largely, we would guess, unaware of this opportunity to have their voices heard by those who comprise the FSCSR.

This is unfortunate.

Because in due course, and before the CMA comes up with their findings from their Market Investigation into the funeral sector, the FSCSR will be seeking “to identify the extent to which the recommendations of HM Inspector of Funerals could be usefully implemented as a statutory system in the rest of the United Kingdom. The FSCSR’s findings and any recommendations will then be presented to Government stakeholders.”


The self appointed group has set up two working groups – one of which has been working for some time on ‘a) a robust and comprehensive code of practice for the funeral directing profession (output 1); and b) an agreed list of premises inspection requirements, to be enforced by both major trade associations (Output 2), and the other particularly focusing on ‘how transparency in relation to services offered, the standard of those services and pricing could be improved‘. (This second FSCSR group, the ‘transparency working group’ has not as yet identified the members who are sitting on it. Which is ironic)

Both working groups are chaired by the former Inspector of Funerals in Scotland, Natalie McKail.

Ms McKail actually left post in June this year.

The post of Inspector of Funerals in Scotland is currently vacant.

There is no HM Inspector of Funerals in England, Wales or Northern Ireland. And now neither is there one in Scotland.

The citation of Ms McKail’s role as a member of the FSCSR Steering Committee in this document  on the FSCSR website, dated July 2019 and noting her as ‘HM Inspector of Funerals’ is therefore factually incorrect and somewhat misleading. 

Anyway, we digress.

Non trade association affiliated funeral directors who are tempted to get in touch with might be interested to note that they will be in fact be sharing their thoughts with the FSCSR Secretariat, which is helpfully being provided by the two funeral trade associations which they have chosen not to join.

(We know of at least one non trade association affiliated funeral director who was not willing to be identified in their letter to the independent chair of the FSCSR as they were concerned about confidentiality, given that the e-mail was landing in an inbox at NAFD).

They might also want to get their skates on. As today is the 30th August and the deadline set for contacting the FSCSR.

Despite the group having been formed in November last year, and the work to attempt to put right the mess that is funeral world having been ongoing since then.

Or, they might do exactly what we have done, and make contact with the CMA directly to express their thoughts about the funeral sector in general, and why they have not chosen to be part of a trade association.

One progressive funeral director has done both – you can read the letter that Louise Winter sent to the independent chair of the FSCSR yesterday here: Letter to Lewis Shand Smith – 29th August 2019

Go on, make a cup of tea and have a read.

You’ve got less than 12 hours to respond anyway.

And we think Louise has said it all.

Fran Hall

Last week, some of Team GFG hosted an extremely interesting meeting in central London, details of which will be shared in due course.

Among our guests were a number of representatives from the Competition and Markets Authority, the body currently carrying out the market investigation into the funeral sector. 

They have asked that we share the appeal below for any information that blog readers might have:

“Do you know of any organisations (care homes, hospices, hospitals etc.) that have a formal or informal arrangement with a funeral director which means that the funeral director provides services without the consent of the deceased’s family?

This could, for instance, include arrangements for the deceased to be transported to a funeral director’s premises on the organisation’s instruction, rather than that of the deceased’s family.

If so, the Competition and Markets Authority (CMA) is interested in hearing from you.

The CMA would like to understand how common these arrangements are. It may then make appropriate follow-up enquiries with the organisations concerned to explore the impact these arrangements may be having on customers.

If you would like to help the CMA, please follow the link to a short Survey Monkey questionnaire, prepared by the CMA, to provide details of these organisations.

Responses will be anonymous, will only be seen by the CMA and will be held securely and confidentially.  

Clicking on the following link (which will be open until Friday 6 September 2019) will take you to the CMA’s questionnaire: 

Fran Hall

Did you see this article in Monday’s Times?

Restaurant style ratings to combat funeral rip-offs’, the headline screams.

It’s behind a paywall, but we can precis it for you. Here’s a direct quote:

“Funeral directors are to be given restaurant-style ratings as the industry battles accusations of over-charging and inconsistent standards.

Classifications based on clarity of prices, conduct of funerals, vehicles and staff training, and mortuary and refrigeration facilities will be issued to thousands of funeral parlours based on inspections of their premises.

Those given the lowest ratings are likely to be ‘reported to their local authority for investigation under consumer protection law.”

The Times article references the new group appointed by the industry to address inconsistency in standards and the lack of transparency in fees, which, it states, is going to produce ratings that funeral directors would have to display in their premises and on their websites, similar to those issues by the Food Standards Agency for restaurants, hotels, supermarkets and care homes.

“Its chairman Lewis Shand Smith, former head of the dispute resolution body Ombudsman Services, told The Times it wanted a tougher code for practices such as collection of the body, care of the deceased and conduct of funerals. It also plans a charter mark system and common inspection regime for the sector in England.

“There is an awareness growing that standards may not be the same across the industry,” Mr Shand Smith said. “The industry itself is concerned that the few can bring the whole industry into disrepute and it is time to correct that.”

It’s unfortunate that the first main press coverage of the work of the FSCSR appears to have got its facts almost completely wrong.

Yesterday, an e-mail was sent out by the FSCSR Secretariat to those involved in the various working and steering and reference groups.

It said: “The article states that the FSCSR will “produce ratings that funeral directors would have to display in their premises and on their websites, similar to those issues by the Food Standards Agency for restaurants, hotels, supermarkets and care homes”.  This is not entirely accurate.

To be clear, no decisions about final project outcomes have yet been made. The possibility of recommending a ratings system may well be discussed by Working group B (the transparency working group) when it meets for the first time on 2 September but nothing has yet been discussed or agreed by any FSCSR working group or committee.”

Who is this FSCSR, we hear you ask?  The Funeral Service Consumer Standards Review? Who are these people? And how can they have had such a catastrophic first introduction to the public?

Readers of the Funeral Director trade magazine will have had a sneak preview of the FSCSR last month. And they have a website, which you can find here.

Names of those on the FSCSR Steering Committee and the FSCSR Working Group A are listed, although, ironically, the members of Working Group B, tasked with looking at transparency, are not yet in the public domain. This is apparently because of GDPR.

 You can read all about the group in their Background Document’. The timetable looks like everything has happened in just the last couple of months, although we understand conference calls and work have been underway since January this year.

Oh, and as yet, no correction to the Times article appears on the new FSCSR website, even though they have a News tab. We’re sure it will, if the facts are so wrong.

Anyway, back to Mr Shand Smith, the independent chair of the FSCSR.

He appeared on BBC Radio Kent earlier yesterday, not exactly refuting the McDonalds’ style star system idea – listen here from 1:47.

When asked about the star system, he said, “I know the suggestion has been made, and the organisation that I’m kind of leading at the moment, we are looking at various ways of making the standards transparent to the public… these discussions are at a very early stage.”

And about the FSCSR: “They started this at the end of last year, they came together and recognised that there was a need, and the industry itself was raising questions about how it could do things better, and so they got together in December and decided to carry out an inquiry that would lead to a number of recommendations. And it’s widespread, it’s the two main trade associations, but a lot of independents as well, people who have an interest in the industry.”

OK, let’s clear up a few things here.

The FSCSR came into being as a direct result of an initiative by Dignity PLC, who are super keen on being seen as good guys by the CMA. (And by their shareholders too probably, given that the share price has now sunk below £5, somewhat of a drop from the 2016 high of £28.71. Luckily, Dignity directors sold £15 million worth of shares before the slump began – see our blog post here )

The inaugural roundtable meeting at Westminster last December was organised and funded by Dignity, as referenced in the Chief Executive’s statement on page 18 of their Annual Report and Accounts 2018: “We therefore continue to lead the call for change as we seek a regulated market that will be good for clients and society. Dignity is working collaboratively with industry partners and other stakeholders to improve standards across the sector. At the end of 2018 we initiated a round table discussion and invited the CMA and other representatives from the funeral sector, co-operating together to try and find a solution.” 

And far from there being a ‘lot of independents’ involved with the FSCSR, as cited by Mr Shand Smith yesterday on the radio, there are just two independent funeral directors, both invited by a phone call from a representative from Dignity at the last minute before the December meeting, when it was suddenly realised that no unaffiliated independent funeral directors had been asked to participate.

We have been assured by the one of the NAFD representatives on the FSCSR that ‘all Steering Committee and working group members were appointed independently, either by Lewis (in respect of Steering Committee members), the Steering Committee and the Working Group Chair, Natalie McKail’, and that ‘both FSCSR Chairs are completely independent and that all participants appear to have come to this project with the right intentions.’

This is good to know.

We know that both of the independent funeral directors invited to take part in the work of the FSCSR have done so with the absolute best of intentions, and with the hope of positively influencing the work under way. They have also both made it very clear to the FSCSR that they represent only themselves, and not any other independent funeral business.

And we also know that both independent funeral directors called strongly from the start for the both Good Funeral Guide and the Natural Death Centre charity to be included in the discussions.

One would have thought that inviting the two organisations that actively work on behalf of bereaved people to inform a group brought together to look at things from the perspective of ‘funeral consumers’ would have been a bit of a no-brainer.

But no invitation was forthcoming.

The independent funeral directors continued to press the case for the GFG and the NDC during calls and by e-mail over the next seven months  We know this because we stayed in contact with them.

We waited. And waited. But we heard nothing.

Then, on August 1st, an e-mail arrived from someone at the NAFD, with an attached letter written on behalf of Mr Shand Smith. We had been invited to the party at last.

We were asked to take a place on the FSCSR Stakeholder Reference Group, (the SRG) with the task of ‘informing, guiding and underpinning’ the work of the FSCSR.

We had a think about it, and then we politely declined, observing that ‘For the Good Funeral Guide to have been invited at this late stage to sit on a ‘Stakeholder Reference Group’ with a stated purpose of informing, guiding and underpinning work which has been underway for months can only be an afterthought. We would expect that ‘informing, guiding and underpinning’ a project would be a requirement from the start.’

We also pointed out, “The issues under scrutiny by the CMA have arisen entirely due to poor practice within the funeral sector, and we consider it is the sole responsibility of those party to the poor practice to attempt to redress this.

The Good Funeral Guide has been wholly critical of poor practice and lack of transparency in the funeral industry for many, many years, and we see no merit in our being involved in the sector’s attempts to pre-empt any recommendations in the CMA’s Final Decision report expected next year.”

In a comprehensive e-mail response received yesterday from the Secretariat of the FSCSR, we were advised that the door was still open for us should we change our minds, and that “the fact that GFG was not approached to sit on a working group does not mean that your opinion isn’t valued by the project… Those making working group appointments simply had to make decisions about who would bring most value to the groups based on the information available to them.”


“I do hope you will take us up on this offer. It would be really good to have the benefit of your experience and perspective on the SRG.”

We appreciate the appeal to re-consider, and assurance of independence and lack of pressure or influence, and that there was “no intention of claiming that SRG members have somehow endorsed the FSCSR project. In the spirit of transparency, we simply want to list the names on the FSCSR website as consulted parties. We would also be happy to openly publish, unedited, any written GFG response to FSCSR documents on the FSCSR website.”

But, our decision stands.

There are plenty of people already working on this. We are content to wait and see what they come up with.

Also, the FSCSR budget appears to be limited – for the work involved at least. We’ve been told more than once that “this is a project with a limited budget and a very ambitious timeframe.” In fact, this was given as the reason for not involving the GFG from the outset.

Despite the group being “funded by the funeral industry through the NAFD, with additional financial support from Golden Charter, Funeral Zone and Ecclesiastical Planning Services.”

One would have thought that for such apparently imperative cross sector working, adequate funding would have been found from the organisations involved. It can’t be costing that much to have a few meetings and create a website.

Oddly, the Times on Monday wrote about the “£2 billion-a-year funeral industry” and noted that “the industry has agreed to spend millions of pounds to publicise the charter marks and ratings system for funeral directors who signup.”

Millions of pounds to publicise something that’s been put together on a limited budget with a very ambitious timeframe?

Perhaps they got that all wrong too.

Fran Hall


Back in November 2017, a bright new star rose in the world of funerals.

St. Margaret’s Hospice in Somerset joined forces in partnership with Howard Hodgson’s Low Cost Funerals to form Hospice Funerals LLP in what they described at the time as ‘one of the biggest developments in the funeral market‘.

According to the same announcement, entering the funeral market was the brainchild of Ann Lee, Chief Executive of St. Margaret’s Hospice.

Encouraged by Mr Hodgson, Ms Lee shared her vision of a franchise operation with attendees at the 2017 Hospice UK conference, and in January 2018 the much heralded first Hospice Funerals branch was opened in Taunton.

Here at the GFG, we had some misgivings about the concept, and we wrote letters to the trustees of all hospices in the UK laying out our concerns – you can read the letter here.

It may be that our warning was heeded, or it may be that trustees of other hospices already shared our concerns about the wisdom of St. Margaret’s Hospice’s vision for the future – either way, in early 2018 Hospice UK issued a statement about their position on the concept, and it appears that there were no takers for the idea of getting on board with the Hospice Funerals scheme.

Notwithstanding, the enthusiasm continued, and in a progress report on March 1st 2019, Ms Lee noted “After a successful first year for our Taunton funeral home, we are recruiting to cope with growing demand and are already working on expansion plans to reach more people in our patch.

St. Margaret’s Hospice Funerals is on track to become an established revenue stream for our charity.” 

Is it?

Let’s look a little more closely.

A browse through Hospice Funerals LLP’s filing history at Companies House shows a flurry of appointments, cessations and terminations of appointments, with Low Cost Funerals terminating their involvement as of 28th March this year.

Hospice Funerals LLP now has a somewhat circular list of officers – Hospice Funerals Trading Ltd, and St. Margaret’s Funerals Ltd.

Both HFTL and SMFL list just one officer – Hospice Funerals LLP. Follow the links and you get back to where you started. No names, no pack drill.

It looks like the partnership between St. Margaret’s and Low Cost Funerals didn’t make it to the sunny uplands of the ‘marriage made in heaven‘, as it was described in a comment when the franchise scheme was launched. Nor does it appear to have been ‘genius‘, as described by a CEO of another hospice.

The micro company accounts of Hospice Funerals LLP can be viewed here. We had to read them twice to make sure we had understood the numbers correctly.

In the period to 31 October 2018,  it appears Hospice Funerals LLP spent an eye-watering amount of £329,567 on administrative expenditure! 

This figure includes £41,731 on conference costs, £71,191 on legal costs, £36,342 on travel, accommodation and subsistence and £23,848 on marketing.

The net profit for the period is shown as (£320,862). For anyone unfamiliar with accounting, the brackets indicate a minus number. So, a loss.

These accounts for Hospice Funerals LLP were published on 31 July 2019.

On the same day, St. Margaret’s Hospice announced plans to close the in patient hospice ward in Yeovil.

The Yeovil unit was built after an appeals committee was founded to raise £4.5 million in 2001. It originally had 16 beds and was officially opened in 2004, complete with state of the art facilities and equipment. The people of Yeovil and the surrounding areas have reacted with fury, calling the decision ‘disgusting’. A Facebook group called “Save St. Margaret’s Hospice Yeovil’ has attracted over 13,000 members in a week.

Full details of the planned closure can be found here, along with background information explaining why the hospice was unable to offer staff a cost of living pay increase earlier this year.

It gives us no pleasure to bring you this update today.