Fran Hall

We thought it was about time to share something with GFG blog readers.

It’s a story that’s been running for a while, but today seems like a really good day to put it in the public domain.

This week, we made a third party observation to the Intellectual Property Office about a pending trademark application.

We would have loved to lodge a formal opposition to the trademark application, but even with the 50p piece we just found down the back of a sofa at GFG Towers, we couldn’t cobble together the money required, so we’re relying on the IPO to read our letter and apply some common sense.


Read on!

Back in 2008, a young, fresh faced Charles Cowling launched the GFG on the world. The website was a labour of love, and he put days and weeks and months of unpaid work into creating a wonderful information resource for people who needed to arrange a funeral. He also started the long running GFG Blog which now boasts over 3,000 posts and opinion pieces.

Funeralworld took notice, and the GFG rapidly acquired a following of all kinds of people, with many lively discussions ensuing in comments on various posts. The website grew in popularity too, with large numbers of people visiting it for advice and information about funerals.

The media liked us too. Charles became a regular on TV and in the papers. (We’ve tried to keep the momentum going – we are frequently approached for comment on coverage of funeral related subjects, and have been referenced and quoted in The Times, The Guardian, The Independent, Metro and other newspapers in recent years, along with interview coverage on BBC TV, ITV, RT, and multiple radio stations.)

Anyway, all seemed well with the world, so much so that in 2011, the Good Funeral Guide became the Good Funeral Guide CIC, a not for profit social enterprise company and was incorporated as such at Companies House. You can read our Community Interest Statement here from page 18 in the filing of ‘Incorporation’.

Our stated purpose is to ‘support, empower and represent the interests of dying and bereaved people living in the UK’, and we take this responsibility very seriously. If we see something that we think is wrong, or that is detrimental to the interests of dying or bereaved people, we say it. Loudly, and often.

This has gained us something of a reputation and brought us a lot of good friends who share our views, but also attracted less welcome attention in the form of occasional threats of legal action from the companies or organisations we have criticised. That’s kind of to be expected – speaking truth to power tends to annoy powerful players who have been called out for doing something we don’t think is ethical or right.

Sometimes we get approached by very nice representatives from the organisations concerned, offering us coffee or dinner or a chance to meet up and find out more about how their employers aren’t really the bad guys we portray them as.

These overtures are always flattering, but never accepted, which means we now have the reputation of being difficult and unfriendly among a certain cohort. (We’re not at all, as anyone who knows us can confirm, but we are passionate and protective about our independence; we hold it as a precious and rare thing in the arena in which we operate).

So, to cut a long story short, the GFG has jogged along since it became a CIC, just about staying afloat financially and maintaining an extraordinarily high listing on Google entirely because of the calibre of the traffic we get to our website. Unsurprisingly, we’ve never had the cash to spare for search engine optimisation, so our high visibility online is entirely due to you, dear reader!

The wonderful thing about being high up on Google is that our impartial and accurate advice is findable by everyone, and tens of thousands of people make use of it every year. We’d like to think that we’re helping to inform and empower people all over the country and as a consequence, enabling large numbers of people to get a better experience organising a funeral than they would otherwise have had.

It’s a responsibility that we take very seriously, and we are immensely proud of the GFG and all that it stands for – and I know I speak for all of the directors of the GFG, both former and current when I say this.

There is nothing like the Good Funeral Guide, it’s unique, and irreplaceable. It’s a jewel. It is wonderful, wonderful entity to be involved with because it has integrity running through its DNA. And in today’s world, this is a rare thing.

Free, expert information for anyone needing to make arrangements for a funeral is something that is very important indeed, we are sure you’ll agree.

And were there to be an attempt to diminish the standing and reach of the Good Funeral Guide, we’re equally sure that you’ll agree that this would be a very, very bad thing.

Well, it appears that something of just this kind of nature has been underway. Whether deliberate or not. It might just be a coincidence.

Cast your eyes over the chronology and see what you think.

  • Back in 2012, a company was incorporated at Companies House on behalf of two directors, Ed Gallois and Kevin Homeyard. Funeralzone operated an internet funeral director comparison site, and many funeral directors will be familiar with it. In fact, many funeral director websites still invite visitors to ‘Read our reviews on Funeralzone’.


  • Over time, a number of funeral directors and others invested in shares in the company. The latest list of shareholders can be found in the Confirmation Statement filed on 5thAugust at Companies House here.


  • Sometime between July 2017 and July 2018, Dignity PLC invests at least £666,000 in Funeral Zone Ltd. The investment could have been circa £1 million – on page 102 of Dignity’s 2017 Annual Report and Accounts, the following reference is made ‘During the period, the Group invested £1 million in a non-controlling interest in a business’.


  • 1 June 2018 the Competition and Markets Authority launches a market study into the funeral sector


  • Between August 2018 and December 2018, Dignity increases its investment in Funeral Zone by a further £5 million. Page 120 of Dignity’s 2018 Annual Report and Accounts states: “As a result of the last investment, the Group has a 23.8 per cent investment. Funeral Zone Limited is a UK online funeral resource for funeral directors and clients and has been invested in for its intellectual property opportunities. The Group holds less than 2 per cent of the voting rights of Funeral Zone Limited but is deemed to have significant influence principally due to holding a right to appoint a board member who would hold a 25 per cent representation on the Board of Directors and therefore has the power to participate in the financial and operating policy decisions. The Group also hold a call option over a further 44.4 per cent of shares.


  • At the end of the period, the Group held an investment of £nil million (2017: £1.0 million) in a non-controlling interest in a business. An additional investment of £0.5 million was made in August 2018 and the fair value was deemed to be cost. Following a further investment of £4.5 million in December 2018 it was concluded that the Group had significant influence over the investment and this has now been accounted for and reclassified as investments in associated undertakings”


  • By January 2019 therefore, Dignity had invested £6 million in Funeral Zone Ltd. This investment is in a company described on the same page of Dignity’s 2018 Annual Reports and Accounts as not making profit: “Funeral Zone Limited had revenue of £3,000 and a total loss for the period since acquisition of £177,000. The Group’s share of loss for the period therefore amounted to £42,000 which has not been shown on the face of the Group’s consolidated income statement.


  • 29 November 2018 the Competition and Markets Authority publishes their Interim Report and consultation on whether to make a market investigation reference.


  • November 2018 Dignity initiates and funds a round table meeting at Westminster as referenced in the Chief Executive statement in the 2018 Annual Report and Accounts page 18 – ‘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.’ This group will go on to name itselftheFuneral Service Consumer Standards Review.


  • 1 December 2018 a third director of Funeral Zone Ltd is appointed. Paul Webb, whose occupation is described as business consultant, joins Ed Gallois and Kevin Homeyard as a co-director. Mr. Webb’s LinkedIn account cites a current role as Business Development Executive at Funeral Homes Ltd, an ‘Acquisitive Funeral Business Group’, and, incorrectly, a second current role as Managing Director of Anderson Maguire Funeral Group Ltd (Companies House indicates Mr. Webb resigned from this position on 23rd November 2016).


  • 8 January 2019 a new company, ‘Funeral Arranger Limited’, was incorporated at Companies House. Ed Gallois is named as the sole shareholder and managing director.


  • 14 January 2019 a Change of Name notice was filed at Companies House. ‘Funeral Arranger Limited’ changes its name to ‘Funeral Guide’.


  • 14 January 2019 Funeral Zone Ltd applies to trademark the name ‘Funeral Guide’at the Intellectual Property Office.


  • 14 January 2019 the domain name changes hands. Formerly owned by Mark Brown and used to sell funeral plans, the new owner is Funeral Zone Ltd. (We wrote about Mr. Brown’s attempts to get his funeral plan flogging business off the ground in a blog post here back in 2017).


  • 28March 2019 the CMA announces a Market Investigation into the funeral sector.


  • 10April 2019 Funeral Zone Ltd applies to trademark the name ‘Arranger’at the IPO.


  • 16 April 2019 Funeral Zone Ltd applies to trademark the name ‘Memoria’ at the IPO.


  • 10April 2019 the IPO refuses the trademark application for the name ‘Funeral Guide’.


  • 14May 2019 Dignity warns of reduced profits.


  • 19 June 2019 First meeting of the Funeral Service Consumer Standards Review Steering Committee. Independently chaired, the committee is made up of ten representatives. Of these individuals, four have business connections with Dignity:
  • Andrew Judd – Dignity Director of Funeral Operations
  • Ed Gallois, Funeral Zone Ltd (23% Dignity owned)
  • James Daley – Fairer Finance (commissioned by Dignity to produce a 2018 report into funeral plans)
  • Jon Levett – National Association of Funeral Directors (funded by membership including 826 Dignity branches)


  • 24 June 2019 Funeral Zone Ltd applies to trademark a figurative version including the words ‘Funeral Guide’ with the IPO.


  • 28June 2019 ‘Arranger’is registered as a trademark belonging to Funeral Zone at the IPO.


  • 5 July 2019 the figurative ‘Funeral Guide’trademark application is published on the IPO website.


  • 16 July 2019 an independent funeral director who had been publicly critical of the investment by Dignity into Funeral Zone receives a letter of claim ‘pursuant to the pre-action protocol for defamation claims’ from Funeral Zone’s solicitors.


  • 17 July 2019 the Funeral Zone comparison site announces it has changed its name to ‘Funeral Guide’. All internet traffic to is now redirected to All website content and social media profiles are changed to reflect the new name and branding. Sponsored facebook posts and twitter tweets appear to publicise this news.


  • 17 July 2019 new Dignity ‘pay per click’ advertisements are noted at the top of the results for the search terms ‘Funeral Guide’ or ‘Good Funeral Guide’.


  • 18 July 2019 a series of 10 free evenings of dinner and drinks for funeral directors is announced around the country showcasing Arranger software. Arranger software is owned by Funeral Zone Ltd.


  • 12 August 2019 an article appears in the Times claiming ‘Funeral Directors are to be given restaurant style ratings as the industry battles claims of over-charging and inconsistent standards.’


  • 13 August 2019 The FSCSR Secretariat sends an e-mail, purportedly to all those involved in the FSCSR, stating that the information in the Times was incorrect.


  • 15 August 2019 a funeral director posts a photo on Facebook announcing ‘Pearson funeral service does it again – 5 star award’. The image is of window stickers showing five gold stars and with the text ‘We have been rated by Funeral Guide, an independent review website’.


For context, back in October 2016, Dignity’s share price was £28.71.

It has fallen consistently since then, closing on Friday 30thAugust 2019 down 83% on that October price,  at £4.69

We also note Funeral Guide has amassed an ENORMOUS following on social media. 

At the time of writing, they boast 12,200 followers on Twitter and a massive 52,368 followers on Facebook. SO many people choosing to follow a funeral comparison site. (For comparison, the GFG Twitter account has 3,341 followers on Twitter, and 1,281 followers on Facebook.)

Oddly, and unlike the GFG followers, those following Funeral Guide on social media are almost completely passive and silent.

Funeral Guide’s posts are rarely commented on and occasionally liked by just a handful of individuals. But to the average person looking at the Funeral Guide profiles on social media, they look like an enormously important and influential organisation with thousands of people waiting for their next post.



We know what we think about all of these shenanigans.

Which is why we have lodged our observations about the attempt to trademark a name so very similar to ours by an organisation that now cites itself as the ‘UK’s definitive online funeral resource’ with the IPO.

We’ve also dropped a note to Companies House about the registration of a company name so like our own. And passed a lot of documentation to the Competition and Markets Authority.

But ultimately, that’s about all we can do.

If we happened to have had £6 million pounds appear on our balance sheets in the last year or so, that would cover a whole lot of expensive fancy lawyers were we to try to defend our position by taking a legal route.

But sadly, 50p won’t go very far at all.

All we have is a public platform to share our concerns.


Fran Hall

We continue to publish the very important observations from funeral directors in response to the invitation from the Funeral Service Consumer Standards Review to make contact, and have great pleasure in adding the contribution from Jo Williamson, of Albany Funerals.


Dear Mr Shand Smith,

It has come to my attention that on 22nd August you issued a call to non-trade association affiliated funeral directors to share their views with the Funeral Service Consumer Standards Review you are currently conducting.

Sadly, as you have only allowed a very short timescale for busy funeral directors to respond (8 days – was this an afterthought?), I have missed the deadline but I would still like to take this opportunity to put forward my views.

We are independent funeral directors based in Kent, in our 10th year of trading.  For the first 7 years we were members of SAIF but were left feeling largely unsupported and unchecked, and therefore made the decision to remain non-affiliated for a few years.  However, we have recently begun the process of joining the NAFD, mainly due to fierce local competition and we felt that we might be viewed as lacking ‘legitimacy’ if we were not members of an association, and there is no other real alternative. 

I cannot agree, however,  that I feel represented by these organisations ‘seated at the table’, as in my experience they do not always seem to be led by the interests of the bereaved person, or the person who has died, but more so in protecting their members, whose practices are sometimes questionable at the very least. 

Although I welcome any initiative to improve standards, I do feel confused that this is being run simultaneously with the Government CMA review, which is a completely independent review as opposed to an ‘industry initiative’ which yours claims to be, and I would also be curious as to how this will be implemented in conjunction with the findings and recommendations of the CMA report?

I have also looked at the Scottish Government Code of Practice Consultation in detail and was alarmed to see that the proposed regulations do not offer any real solution to prevent the exploitation of the vulnerability of bereaved people and the lack of transparency of the funeral industry, which are the two main areas of concern highlighted by the CMA. 

Moreover, some of the regulations proposed fall incredibly short, for example, although the Scottish Government ‘believes that the use of refrigeration is a critical element of caring for a deceased person in a dignified, appropriate and respectful manner’, they concur with SAIF’s recommendations that a mere ratio of 1:50 is acceptable (1 refrigerated space per 50 funerals)! 

This does not fill me with confidence going forward, particularly as your working groups are heavily represented by these trade associations and large corporations, that obviously benefit from such loose and misleading regulations.  It is very clear to me that any regulation of the industry should be entirely independent and not decided by stakeholders.  For a start an independent ombudsman should be reinstated so that when things do go wrong, consumers have somewhere to turn to.

My recommendation would be the following: to focus on the protecting the bereaved and their families/friends and not the funeral director

Instead of regulations, I believe it would be more productive and successful to produce an ethical code of conduct.  In 7 years, SAIF did not once inspect my mortuary or any of our funeral processes or procedures.  The inspection would consist of a cosy chat in the office and the advice to ensure that a ‘no smoking’ sign is displayed somewhere visible. 

Because of this lack of scrutiny, it has become easy for funeral directors to act to suit their own interests.  These are a few examples of things that happen ROUTINELY in many businesses, that we see and hear about on a DAILY basis:

  • families given funeral dates 4/5 weeks after death to suit the diaries of the funeral directors
  • routine embalming (often without permission) to avoid having to use refrigeration
  • moving bodies about without permission from families to off-site storage units or for viewing purposes
  • inadequate or no refrigeration at premises
  • embalming taking place with inadequate facilities (bodies on the floor)
  • overselling of funeral products
  • huge mark ups on products
  • funeral directors giving funeral quotes based on the type of car the consumer has
  • tacit agreements with care homes/hospices to provide services for free in return for referrals
  • limited time set for funeral arrangements (sometimes 40 mins)
  • rewards/penalties for funeral plan or memorial selling
  • clothes intended to dress the person who has died placed in the coffin still in the bag presented by the family

I can only hope that as you are independent as chair of this committee, that my letter might lead you explore some of these concerns and take them seriously.

Thank you for your time,

Kind regards,


Jo Williamson


Fran Hall

Today we have the pleasure of publishing a letter from Jo Vassie, of Higher Ground Family Funerals, which was sent to the Competition and Markets Authority a few weeks ago.

We thought that the Funeral Service Consumer Standards Review might also find it interesting reading. 


Dear Sirs,

I’m am writing to express my thoughts and worries regarding the new legislation for Scotland and am concerned that similar will follow for the England.

I am 70 and still fully occupied with work along with my husband and son. We opened a natural burial ground 10 years ago, very soon individuals were securing their plots for eventually and very many asked me if I could deal with their funeral when the time came. The answer had to be no.

Once our son joined us in the business, this became a possibility and so we set to and converted a farm building into a beautiful facility, giving us a meeting room, visiting room, mortuary and garaging for our vehicle, which is not a hearse but an adapted people carrier ( work done by son)

This has been the most incredible experience; we have received very many emails and letters of thanks from our families. We have no qualifications, we just treat people as we would wish to be treated, this includes the family arranging the funeral and of course the person who has died.

Locally we have St Margaret’s Hospice, who last year caused quite a stir when they entered into the funeral world. Their start-up costs were ridiculous and so the venture has made a huge loss and it is thought that this has had a knock on effect that they are closing their inpatient beds in their Yeovil hospice.

I am very concerned that legislation will be brought in for training and qualifications – please tell me how this will ensure that everything is exemplary in funeral homes? 

I have no objections in my premises being inspected and chose to be a recommended funeral provider by The Good Funeral Guide, this just gives the public an independent opinion. But the best recommendation comes from families whom we have served.

If it becomes compulsory for training and belonging to SAIF or NAFD, it will increase set up costs for independent people like ourselves and will not prevent bad practice.

The net result is the public will be the losers.

Kind regards,

Joanna Vassie

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.

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