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This draft code guidance has not been signed off by the FSCSR Steering Committee and is presented for consultation purposes only.

Application of the Code

The FSCSR Code can be accessed here.

This Code applies to all funeral directors. 

For the purposes of this Code a funeral director is defined as: 

“A person or organisation whose primary activities consist of, or includes the arrangement and conduct of funerals.”

For the avoidance of doubt, this definition includes all of the following:

    • Funeral businesses, including sole traders and partnerships
    • Funeral business owners
    • Funeral business staff who routinely come into direct contact with bereaved families
    • Embalmers
    • Funeral business staff responsible for arranging funerals
    • Funeral business staff responsible for the care or transport of deceased people
    • Managers of funeral business staff
    • Funeral business managers
    • Anyone who sells funerals

How to use this guidance

Mandatory provisions of the Code

The following provisions are mandatory:

The Code Principles
The Code Principles define the fundamental ethical and professional standards expected of funeral directors when providing funeral services. You should always have regard to the Principles and use them as your starting point when faced with an ethical dilemma.
Where two or more Principles come into conflict the one which takes precedence is the one which best serves the public interest in the particular circumstances.

The Outcomes (O)
The outcomes describe what funeral directors are expected to achieve in order to comply with the relevant Code Principles in the context of the relevant part of the Code. 

Any failure by a funeral director to operate in accordance with the mandatory provisions will constitute a breach of this Code. However, not every breach of the Code will result in disciplinary action by a regulator.

A printer-friendly version of the Code can be accessed here.

Non-mandatory indicative behaviours

The following provisions are not mandatory:

Indicative Behaviours (IB)
The outcomes are supplemented by indicative behaviours. The indicative behaviours specify, but do not constitute an exhaustive list of, the kind of behaviour which may establish compliance with, or contravention of the Code Principles. These are not mandatory but they may help your regulators to decide whether an outcome has been achieved in compliance with the Code Principles.

The Code recognises that there may be multiple ways of achieving the Outcomes. If you choose a different method from those described as Indicative Behaviours, you should be prepared to demonstrate how you have nevertheless achieved the Outcome. It is advisable to carefully consider how you can best achieve the outcomes, taking into account the size of your business, the particular circumstances of the matter and, crucially, the needs of your clients.

Code principles

This Code is founded on the following ten mandatory principles. Any failure to operate in accordance with these principles will constitute a breach of this Code.

Funeral directors must:

  1. act in the best interests of each client, prospective client and customer;
  2. provide the best possible level of care to the bereaved, keeping in mind the specific needs of each client and family;
  3. respect and maintain the dignity of deceased people in their care at all times;
  4. act with honesty and integrity;
  5. provide clients with full and fair information about services, products and associated costs; 
  6. behave in a way that promotes and maintains public trust in their business, the funeral directing profession and related trades;
  7. comply with all legal and regulatory obligations and deal with their regulators in an open, timely and cooperative manner;
  8. run their business effectively and in accordance with proper governance and sound risk management principles;
  9. run their business in a way that encourages equality of opportunity and respect for diversity; 
  10. run their business in a way that encourages a culture that values and welcomes complaints as a way of putting things right and improving service; and
  11. conduct appropriate due diligence in relation to all third-party relationships that have the potential to negatively impact their clients.

Part 1: Caring for your clients

This part is about providing a proper standard of service, which takes into account the individual needs and circumstances of each client and bereaved family. This includes providing clients with the information they need to make informed decisions about the services and products they require, how these will be delivered and how much they will cost. This will enable you and your client to understand each other’s needs, expectations and responsibilities. 

Your relationship with your client is a contractual one which carries with it legal, as well as conduct, obligations. This part focuses on your obligations in conduct.

You are generally free to decide whether or not to act for a client in any matter, provided you do not discriminate unlawfully (see Part 7).

Outcomes 

You must achieve these outcomes:

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(1.5). after taking instructions, you promptly provide your client with a clear printed or written itemised estimate that clearly states why each charge has been included;

IB(1.6). estimates you provide state clearly which costs are attributable to the you and which costs will be paid to a third party on the client’s behalf. Third parties are named wherever possible;

IB(1.8). you provide clients with a written itemised final account that is comparable with the written estimate provided. Any changes from the estimate to the final bill are clearly described;

IB(1.13). you clearly explain any limitations or conditions on what you can do for the client, for example, because of the terms of a pre-paid funeral plan;

IB(1.14). in taking instructions and during the course of your interactions with your client, you have proper regard to your client’s mental capacity or other vulnerability, such as vulnerability due to bereavement;

IB(1.15). you clearly explain your fees to your client;

IB(1.16). you explain in advance about any other payments for which the client may be responsible;

IB(1.17). you discuss how the client will pay, including whether state financial support may be available;

IB(1.18). you provide information in a clear and accessible form which is appropriate to the needs and circumstances of the client; and

IB(1.19). you ensure that disbursements included in your bill reflect the actual amount spent or to be spent on behalf of the client.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the Principles:

IB(1.23). acting otherwise than in accordance with your client’s instructions (except when to do so would place you in breach of the requirements of this Code); and

IB(1.24). ceasing to act for a client without good reason and without providing reasonable notice.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(1.12). you take time  to understand and agree the level of service your client requires; and

IB(1.13). you clearly explain any limitations or conditions on what you can do for the client, for example, because of the terms of a pre-paid funeral plan.

Please also see Part 6 of this Code – Training and Professional Development.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(1.4). you make your client aware of the full range of price options available in relation to each major purchasing decision;

IB(1.12). you take time to understand and agree the level of service your client requires; 

IB(1.13). you clearly explain any limitations or conditions on what you can do for the client, for example, because of the terms of a pre-paid funeral plan;

IB(1.14). in taking instructions and during the course of your interactions with your client, you have proper regard to your client’s mental capacity or other vulnerability, such as vulnerability due to bereavement;

IB(1.17). you discuss how the client will pay, including whether state financial support may be available;

IB(1.18). you provide information in a clear and accessible form which is appropriate to the needs and circumstances of the client; and

IB(1.24). In relation to cremation funerals, if you take instructions from someone other than the cremation applicant you make clear that you may not be able to releases the ashes/cremated remains to them without the applicant’s consent.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(1.1). your full pricing information is made available in a predominant position on your business website;

IB(1.2). if you do not have a business website, your full pricing information is made available on some other accessible online platform. This should include information about the price or pricing options of any necessary disbursements;

IB(1.3). any funeral service packages offered are described clearly, with each component part being listed separately on your itemised price list so that any discount applied to the package can be easily identified;

IB(1.4). you make your client aware of the full range of price options available in relation to each major purchasing decision;

IB.(1.7). your estimates and other confirmation documents can be easily taken away if the client requires some time to compare the options available to them;

IB(1.9). you actively encourage your client to go away and take some time to make a purchasing decision before agreeing to a particular level of service;

IB(1.10). you encourage your client to discuss their purchasing decisions with friends and family before entering into a contractual agreement with you;

IB(1.11). you enable clients to make final purchasing decisions away from your funeral home, either online, via telephone or using specialist software;

IB(1.13). you clearly explain any limitations or conditions on what you can do for the client, for example, because of the terms of a pre-paid funeral plan;

IB(1.14). in taking instructions and during the course of your interactions with your client, you have proper regard to your client’s mental capacity or other vulnerability, such as vulnerability due to bereavement;

IB(1.15). you clearly explain your fees to your client;

IB(1.16). you explain in advance about any other payments for which the client may be responsible;

IB(1.17). you discuss how the client will pay, including whether state financial support may be available; and

IB(1.18). you provide information in a clear and accessible form which is appropriate to the needs and circumstances of the client.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(1.25). only providing basic details (e.g. “prices from”) on your website.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(1.1). your full pricing information is made available in a predominant position on your business website;

IB(1.2). if you do not have a business website, your full pricing information is made available on some other accessible online platform. This should include information about the price or pricing options of any necessary disbursements; and

IB(1.3). any funeral service packages offered are described clearly, with each component part being listed separately on your itemised price list so that any discount applied to the package can be easily identified.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(1.25). only providing basic details (e.g. “prices from”) on your website.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(1.3). any funeral service packages offered are described clearly, with each component part being listed separately on your itemised price list so that any discount applied to the package can be easily identified;

IB(1.4). you make your client aware of the full range of price options available in relation to each major purchasing decision;

IB(1.5). after taking instructions, you promptly provide your client with a clear printed or written itemised estimate that clearly states why each charge has been included;

IB(1.6). estimates you provide state clearly which costs are attributable to the you and which costs will be paid to a third party on the client’s behalf. Third parties are named wherever possible;

IB.(1.7). your estimates and other confirmation documents can be easily taken away if the client requires some time to compare the options available to them;

IB(1.8). you provide clients with a written itemised final account that is comparable with the written estimate provided. Any changes from the estimate to the final bill are clearly described;

IB(1.13). you clearly explain any limitations or conditions on what you can do for the client, for example, because of the terms of a pre-paid funeral plan;

IB(1.15). you clearly explain your fees to your client;

IB(1.16). you explain in advance about any other payments for which the client may be responsible;

IB(1.17). you discuss how the client will pay, including whether state financial support may be available; and

IB(1.19). you ensure that disbursements included in your bill reflect the actual amount spent or to be spent on behalf of the client.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(1.20). You only accept instructions from (or on behalf of) a single client in relation to each funeral;

IB(1.21). When approached by more than one prospective client, you make clear that only one person can act as your client and explain the legal consequences of this;

IB(1.22). You have a clear policy on taking instructions from a third-party (e.g. a family member) on behalf of your client;

IB(1.23). In relation to cremation funerals, if you take all practicable steps to ensure that you do not take instructions from someone other than the cremation applicant; and

IB(1.24). In relation to cremation funerals, if you take instructions from someone other than the cremation applicant you make clear that you may not be able to releases the ashes/cremated remains to them without the applicant’s consent.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(1.20). You only accept instructions from (or on behalf of) a single client in relation to each funeral;

IB(1.21). When approached by more than one prospective client, you make clear that only one person can act as your client and explain the legal consequences of this;

IB(1.22). You have a clear policy on taking instructions from a third-party (e.g. a family member) on behalf of your client;

IB(1.23). In relation to cremation funerals, if you take all practicable steps to ensure that you do not take instructions from someone other than the cremation applicant; and

IB(1.24). In relation to cremation funerals, if you take instructions from someone other than the cremation applicant you make clear that you may not be able to releases the ashes/cremated remains to them without the applicant’s consent.

Full list of Part 1 Indicative behaviours

Acting in the following way(s) may tend to show that you have achieved these outcomes and therefore complied with the Principles:

Providing information to clients

IB(1.1). your full pricing information is made available in a predominant position on your business website;

IB(1.2). if you do not have a business website, your full pricing information is made available on some other accessible online platform. This should include information about the price or pricing options of any necessary disbursements;

IB(1.3). any funeral service packages offered are described clearly, with each component part being listed separately on your itemised price list so that any discount applied to the package can be easily identified;

IB(1.4). you make your client aware of the full range of price options available in relation to each major purchasing decision;

IB(1.5). after taking instructions, you promptly provide your client with a clear printed or written itemised estimate that clearly states why each charge has been included;

IB(1.6). estimates you provide state clearly which costs are attributable to the you and which costs will be paid to a third party on the client’s behalf. Third parties are named wherever possible;

IB.(1.7). your estimates and other confirmation documents can be easily taken away if the client requires some time to compare the options available to them; and

IB(1.8). you provide clients with a written itemised final account that is comparable with the written estimate provided. Any changes from the estimate to the final bill are clearly described;

Selling responsibly to bereaved consumers

IB(1.9). you actively encourage your client to go away and take some time to make a purchasing decision before agreeing to a particular level of service;

IB(1.10). you encourage your client to discuss their purchasing decisions with friends and family before entering into a contractual agreement with you; 

IB(1.11). you enable clients to make final purchasing decisions away from your funeral home, either online, via telephone or using specialist software;

Providing a good level of service to your client

IB(1.12). you take time  to understand and agree the level of service your client requires; 

IB(1.13). you clearly explain any limitations or conditions on what you can do for the client, for example, because of the terms of a pre-paid funeral plan;

IB(1.14). in taking instructions and during the course of your interactions with your client, you have proper regard to your client’s mental capacity or other vulnerability, such as vulnerability due to bereavement;

Fee arrangements with your client

IB(1.15). you clearly explain your fees to your client;

IB(1.16). you explain in advance about any other payments for which the client may be responsible;

IB(1.17). you discuss how the client will pay, including whether state financial support may be available;

IB(1.18). you provide information in a clear and accessible form which is appropriate to the needs and circumstances of the client;

IB(1.19). you ensure that disbursements included in your bill reflect the actual amount spent or to be spent on behalf of the client;

Family disputes

IB(1.20). You only accept instructions from (or on behalf of) a single client in relation to each funeral;

IB(1.21). When approached by more than one prospective client, you make clear that only one person can act as your client and explain the legal consequences of this;

IB(1.22). You have a clear policy on taking instructions from a third-party (e.g. a family member) on behalf of your client;

IB(1.23). In relation to cremation funerals, if you take all practicable steps to ensure that you do not take instructions from someone other than the cremation applicant; and

IB(1.24). In relation to cremation funerals, if you take instructions from someone other than the cremation applicant you make clear that you may not be able to releases the ashes/cremated remains to them without the applicant’s consent.

Acting in the following way(s) may tend to show that you have not achieved these outcomes and therefore not complied with the Principles:

Accepting and refusing instructions

IB(1.23). acting otherwise than in accordance with your client’s instructions (except when to do so would place you in breach of the requirements of this Code);

IB(1.24). ceasing to act for a client without good reason and without providing reasonable notice; and

Transparency of pricing information

IB(1.25). only providing basic details (e.g. “prices from”) on your website.

Part 2: Your operational facilities

This part is about ensuring you have access to suitable premises and equipment to enable you and your staff to provide a proper standard of care for the deceased people who are entrusted to your care.

Outcomes 

You must achieve these outcomes:

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(2.2). You carry out annual assessments of your refrigeration capacity requirements to help ensure you can make adequate provision for the year ahead;

IB(2.3). You never take more deceased people into your care than you can accommodate in suitable refrigerated spaces; and

IB(2.4) You have access to mortuary equipment that can accommodate a wide-range of body types.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(2.7). You rely predominantly on the use of hospital mortuary facilities to store deceased people prior to burial or cremation.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(2.5) You keep an up to date list of persons authorised to access you mortuary facilities; and

IB(2.6) entrances to areas in which deceased people are kept are lockable and kept locked when not in use by an authorised person.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(2.1). the refrigeration facilities you use are backed up by a secondary power source or temperature drop notification system and are kept between 4-7 degrees Celsius when in use;

IB(2.2). You carry out annual assessments of your refrigeration capacity requirements to help ensure you can make adequate provision for the year ahead; and

IB(2.4) You have access to mortuary equipment that can accommodate a wide-range of body types.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(2.2). You carry out annual assessments of your refrigeration capacity requirements to help ensure you can make adequate provision for the year ahead; and

IB(2.3). You never take more deceased people into your care than you can accommodate in suitable refrigerated spaces.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(2.7). You rely predominantly on the use of hospital mortuary facilities to store deceased people prior to burial or cremation.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(2.2). You carry out annual assessments of your refrigeration capacity requirements to help ensure you can make adequate provision for the year ahead;

IB(2.3). You never take more deceased people into your care than you can accommodate in suitable refrigerated spaces; and

IB(2.4) You have access to mortuary equipment that can accommodate a wide-range of body types. 

Full list of Part 2 Indicative behaviours

Acting in the following way(s) may tend to show that you have achieved these outcomes and therefore complied with the Principles:

IB(2.1). the refrigeration facilities you use are backed up by a secondary power source or temperature drop notification system and are kept between 4-7 degrees Celsius when in use;

IB(2.2). You carry out annual assessments of your refrigeration capacity requirements to help ensure you can make adequate provision for the year ahead;

IB(2.3). You never take more deceased people into your care than you can accommodate in suitable refrigerated spaces;

IB(2.4) You have access to mortuary equipment that can accommodate a wide-range of body types;

IB(2.5) You keep an up to date list of persons authorised to access you mortuary facilities; and

IB(2.6) entrances to areas in which deceased people are kept are lockable and kept locked when not in use by an authorised person.

Acting in the following way(s) may tend to show that you have not achieved these outcomes and therefore not complied with the Principles:

IB(2.7). You rely predominantly on the use of hospital mortuary facilities to store deceased people prior to burial or cremation.

Part 3: Caring for deceased people

This part is about providing a proper standard of care for the deceased people who are entrusted to your care and ensuring you only act when authorised to do so. 

Any references to “deceased people” or a “deceased person” in this part should be construed as also referring to cremated remains.

Outcomes 

You must achieve these outcomes:

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(3.8). you ensure all deceased people in your care are appropriately clothed or covered when not being actively cared for;

IB(3.9). where possible, you use a modesty cloth or other suitable covering to cover the genitalia and other sensitive body areas of deceased people when they are being actively cared for (e.g. during the embalming process);

IB(3.10). you use an appropriate headblock to support the heads of all deceased people stored in your mortuary facility; and

IB(3.11). you use a newly cleaned and disinfected tray for each deceased person you store in your mortuary facility.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(3.12). You refuse to release cremated remains/ashes to a family until your outstanding bill is paid; and

IB(3.13). You directly mark the body of a deceased person in your care for identification purposes.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(3.1). at the point you are first contacted in relation to the death of an individual, you seek to establish and record the following minimum information:

  1. full name of contact;
  2. whether the death has been confirmed by a medical professional;
  3. contact phone number for the contacting person;
  4. address of the contacting person;
  5. name and contact details for the client (if different);
  6. full name of the deceased person;
  7. address of the deceased person;
  8. date of birth of the deceased person; and
  9. location of the deceased person.

IB(3.2). Before taking a deceased person into your care you obtain signed authorisation or, in the case that the client is not present (e.g. out of hours collection from a care home or hospital), written acknowledgement of the transfer of the deceased person and your being asked to do so.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(3.2). Before taking a deceased person into your care you obtain signed authorisation or, in the case that the client is not present (e.g. out of hours collection from a care home or hospital), written acknowledgement of the transfer of the deceased person and your being asked to do so; and

IB.(3.5) You have in place a cremated remains/ashes management policy that deals with:

  1. procedures for recording individual ashes;
  2. procedures for the splitting of ashes, including the transfer of ashes from one container to another;
  3. a clear description of the options available to client e.g., scattering, interment, retention in an urn;
  4. procedures for the transfer or release of ashes, including procedures for contacting clients and obtaining signatures for release;
  5. procedures for reporting lost or damaged ashes to your client, trade body and any other regulator;
  6. recording of the scattering or interment of ashes if undertaken by the funeral director; and
  7. the keeping of an audit trail of all actions taken with the ashes.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(3.3). You keep an electronic or written log of the details of all deceased people and property you take into your care and ensure that this is backed up regularly;

IB(3.4). You place a completed identity wrist tag, or other form of appropriate identification marker,  upon each deceased person in your care;

IB.(3.5) You have in place a cremated remains/ashes management policy that deals with:

  1. procedures for recording individual ashes;
  2. procedures for the splitting of ashes, including the transfer of ashes from one container to another;
  3. a clear description of the options available to client e.g., scattering, interment, retention in an urn;
  4. procedures for the transfer or release of ashes, including procedures for contacting clients and obtaining signatures for release;
  5. procedures for reporting lost or damaged ashes to your client, trade body and any other regulator;
  6. recording of the scattering or interment of ashes if undertaken by the funeral director; and
  7. the keeping of an audit trail of all actions taken with the ashes.

IB(3.7). You carry out an assessment of the condition of each deceased person in your care at least once in every 24 hour period (this provision does not apply to cremated remains/ashes).

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(3.6). Any cremated remains/ashes in your care are stored securely, along with the relevant cremation certificate.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(3.3). You keep an electronic or written log of the details of all deceased people and property you take into your care and ensure that this is backed up regularly.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(3.6). Any cremated remains/ashes in your care are stored securely, along with the relevant cremation certificate.

Full list of Part 3 Indicative behaviours

Acting in the following way(s) may tend to show that you have achieved these outcomes and therefore complied with the Principles:

Information gathering and record keeping

IB(3.1). at the point you are first contacted in relation to the death of an individual, you seek to establish and record the following minimum information:

  1. full name of contact;
  2. whether the death has been confirmed by a medical professional;
  3. contact phone number for the contacting person;
  4. address of the contacting person;
  5. name and contact details for the client (if different);
  6. full name of the deceased person;
  7. address of the deceased person;
  8. date of birth of the deceased person; and
  9. location of the deceased person;

IB(3.2). Before taking a deceased person into your care you obtain signed authorisation or, in the case that the client is not present (e.g. out of hours collection from a care home or hospital), written acknowledgement of the transfer of the deceased person and your being asked to do so;

IB(3.3). You keep an electronic or written log of the details of all deceased people and property you take into your care and ensure that this is backed up regularly;

Identification and care of the deceased

IB(3.4). You place a completed identity wrist tag, or other form of appropriate identification marker,  upon each deceased person in your care;

IB.(3.5) You have in place a cremated remains/ashes management policy that deals with:

  1. procedures for recording individual ashes;
  2. procedures for the splitting of ashes, including the transfer of ashes from one container to another;
  3. a clear description of the options available to client e.g., scattering, interment, retention in an urn;
  4. procedures for the transfer or release of ashes, including procedures for contacting clients and obtaining signatures for release;
  5. procedures for reporting lost or damaged ashes to your client, trade body and any other regulator;
  6. recording of the scattering or interment of ashes if undertaken by the funeral director; and
  7. the keeping of an audit trail of all actions taken with the ashes;

IB(3.6). Any cremated remains/ashes in your care are stored securely, along with the relevant cremation certificate;

IB(3.7). You carry out an assessment of the condition of each deceased person in your care at least once in every 24 hour period (this provision does not apply to cremated remains/ashes);

Preserving the dignity of the deceased

IB(3.8). you ensure all deceased people in your care are appropriately clothed or covered when not being actively cared for;

IB(3.9). where possible, you use a modesty cloth or other suitable covering to cover the genitalia and other sensitive body areas of deceased people when they are being actively cared for (e.g. during the embalming process);

IB(3.10). you use an appropriate headblock to support the heads of all deceased people stored in your mortuary facility; and

IB(3.11). you use a newly cleaned and disinfected tray for each deceased person you store in your mortuary facility.

Acting in the following way(s) may tend to show that you have not achieved these outcomes and therefore not complied with the Principles:

Preserving the dignity of the deceased

IB(3.12). You refuse to release cremated remains/ashes to a family until your outstanding bill is paid; and

IB(3.13). You directly mark the body of a deceased person in your care for identification purposes.

Part 4: Management of your business

This part is about the management and supervision of your business.

Factors to be taken into account will include the size and complexity of the business; the number, experience and qualifications of the employees; and the number of branches.

The outcomes in this part show how the Principles apply in the context of the management of your business.

Outcomes 

You must achieve these outcomes:

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(4.5). You ensure every member of staff is informed in writing of the identity of their line manager.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(4.1). You actively monitor financial, operational and business continuity risks including complaints, credit risks, equipment/utility failures and damage to premises; and

IB(4.2). you have in place contingency arrangements for the continuation of your business in the event of absences and emergencies, for example an influenza pandemic, with the minimum interruption to funeral services.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(4.1). You actively monitor financial, operational and business continuity risks including complaints, credit risks, equipment/utility failures and damage to premises;

IB(4.2). you have in place contingency arrangements for the continuation of your business in the event of absences and emergencies, for example an influenza pandemic, with the minimum interruption to funeral services; and

IB(4.3). you have a clear written whistle-blowing policy that encourages members of staff to come forward and voice concerns about suspected misconduct, illegal acts or serious non-compliance with this Code.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(4.6). You appoint and train members of staff to take responsibility for monitoring compliance with health and safety and data protection requirements; and

Please also see Part 6 of this Code – Training and Professional Development.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(4.3). you have a clear written whistle-blowing policy that encourages members of staff to come forward and voice concerns about suspected misconduct, illegal acts or serious non-compliance with this Code; and

IB(4.6). You appoint and train members of staff to take responsibility for monitoring compliance with health and safety and data protection requirements.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(4.4). you regularly review your professional indemnity insurance to ensure that it remains adequate to meet a potential claim.

Full list of Part 4 indicative behaviours

Acting in the following way(s) may tend to show that you have achieved these outcomes and therefore complied with the Principles:

IB(4.1). You actively monitor financial, operational and business continuity risks including complaints, credit risks, equipment/utility failures and damage to premises;

IB(4.2). you have in place contingency arrangements for the continuation of your business in the event of absences and emergencies, for example an influenza pandemic, with the minimum interruption to funeral services;

IB(4.3). you have a clear written whistle-blowing policy that encourages members of staff to come forward and voice concerns about suspected misconduct, illegal acts or serious non-compliance with this Code;

IB(4.4). you regularly review your professional indemnity insurance to ensure that it remains adequate to meet a potential claim;

IB(4.5). You ensure every member of staff is informed in writing of the identity of their line manager; and

IB(4.6). You appoint and train members of staff to take responsibility for monitoring compliance with health and safety and data protection requirements.

Part 5: Publicity and the ethical procurement of business

This part is about the manner in which you publicise your business. The overriding concern is that publicity is not misleading and is sufficiently informative to ensure that clients and others can make informed choices.

The outcomes in this part show how the Principles apply in the context of publicity.

Outcomes

You must achieve these outcomes:

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(5.1). where you and another business jointly market services, the nature of the services provided by each business is clear.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(5.4). allowing any other person to conduct publicity for your business in a way that would breach the Principles of this Code;

IB(5.5). advertising an estimated service charge which is pitched at an unrealistically low level;

IB(5.6). advertising an estimated or fixed package fee without making it clear that additional charges may be payable, if that is the case; and

IB(5.7). advertising your business in a way that suggests that services provided by another business (e.g. care and storage of deceased people) are provided by your firm.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(5.5). advertising an estimated service charge which is pitched at an unrealistically low level; and

IB(5.6). advertising an estimated or fixed package fee without making it clear that additional charges may be payable, if that is the case.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(5.3). approaching people in the street, at civic buildings, or in hospitals.

Full list of Part 5 indicative behaviours

Acting in the following way(s) may tend to show that you have achieved these outcomes and therefore complied with the Principles:

IB(5.1). where you and another business jointly market services, the nature of the services provided by each business is clear.

Acting in the following way(s) may tend to show that you have not achieved these outcomes and therefore not complied with the Principles:

IB(5.3). approaching people in the street, at civic buildings, or in hospitals;

IB(5.4). allowing any other person to conduct publicity for your business in a way that would breach the Principles of this Code;

IB(5.5). advertising an estimated service charge which is pitched at an unrealistically low level;

IB(5.6). advertising an estimated or fixed package fee without making it clear that additional charges may be payable, if that is the case; and

IB(5.7). advertising your business in a way that suggests that services provided by another business (e.g. care and storage of deceased people) are provided by your firm.

Part 6: Training and professional development

This part is about ensuring that you and any staff you employ are equipped with the skills, knowledge and experience necessary to provide a proper level of care to bereaved families and the deceased people they entrust into your care.

Outcomes

You must achieve these outcomes:

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(6.1). You and your staff keep a personal development record and take responsibility for your continued learning; and

IB(6.3). You regularly review the training needs of your staff and invest in appropriate training and/or qualifications, relevant to the role undertaken.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(6.5). staff are unaware of their legal and conduct obligations.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(6.1). You and your staff keep a personal development record and take responsibility for your continued learning;

IB(6.2). You require your staff to keep up to date with industry developments and devote time every month to their continued personal development; and

IB(6.3). You regularly review the training needs of your staff and invest in appropriate training and/or qualifications, relevant to the role undertaken.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(6.4). You rely solely on past experience to inform your work as a funeral director; and

IB(6.5). staff are unaware of their legal and conduct obligations.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(6.2). You require your staff to keep up to date with industry developments and devote time every month to their continued personal development; and

IB(6.3). You regularly review the training needs of your staff and invest in appropriate training and/or qualifications, relevant to the role undertaken.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(6.4). You rely solely on past experience to inform your work as a funeral director; and

IB(6.5). staff are unaware of their legal and conduct obligations.

Full list of Part 6 indicative behaviours

Acting in the following way(s) may tend to show that you have achieved these outcomes and therefore complied with the Principles:

IB(6.1). You and your staff keep a personal development record and take responsibility for your continued learning;

IB(6.2). You require your staff to keep up to date with industry developments and devote time every month to their continued personal development; and

IB(6.3). You regularly review the training needs of your staff and invest in appropriate training and/or qualifications, relevant to the role undertaken.

Acting in the following way(s) may tend to show that you have not achieved these outcomes and therefore not complied with the Principles:

IB(6.4). You rely solely on past experience to inform your work as a funeral director; and

IB(6.5). staff are unaware of their legal and conduct obligations.

Part 7: Equality and diversity

This part is about encouraging equality of opportunity and respect for diversity, and preventing unlawful discrimination, in your relationship with your clients and others. The requirements apply in relation to age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation.

Everyone needs to contribute to compliance with these requirements, for example by treating each other, and clients, fairly and with respect, by embedding such values in the workplace and by challenging inappropriate behaviour and processes. Your role in embedding these values will vary depending on your role.

As a matter of general law you must comply with requirements set out in legislation – including the Equality Act 2010 – as well as the conduct duties contained in this part.

The outcomes in this part show how the Principles apply in the context of equality and diversity. 

Outcomes

You must achieve these outcomes:

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(7.1). having a written equality and diversity policy (which may be contained within one or more documents, including one or more policy documents, as appropriate) which is appropriate to the size of the firm and includes the following features:

  1. a commitment to the principles of equality and diversity and legislative requirements;
  2. a requirement that all employees and managers comply with the outcomes;
  3. provisions to encompass your recruitment and interview processes;
  4. details of how you will implement, monitor, evaluate and update the policy;
  5. details of how you will ensure equality in relation to the treatment of employees, managers, clients and third parties instructed in connection with client matters;
  6. details of how complaints and disciplinary issues are to be dealt with;
  7. details of the firm’s arrangements for workforce diversity monitoring; and
  8. details of how the firm will communicate the policy to employees, managers and clients;

IB(7.2). providing employees and managers with training and information about complying with equality and diversity requirements; and

IB(7.3). monitoring and responding to issues identified by your policy and reviewing and updating your policy.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(7.4). being subject to any decision of a court or tribunal of the UK , that you have committed, or are to be treated as having committed, an unlawful act of discrimination;

IB(7.5). discriminating unlawfully when accepting or refusing instructions to act for a client; and

IB(7.6). Acting in accordance with your client’s instructions when doing so would unlawfully discriminate against a protected group (e.g. requesting a celebrant of a particular ethnicity on behalf of your client). 

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(7.1). having a written equality and diversity policy (which may be contained within one or more documents, including one or more policy documents, as appropriate) which is appropriate to the size of the firm and includes the following features:

  1. a commitment to the principles of equality and diversity and legislative requirements;
  2. a requirement that all employees and managers comply with the outcomes;
  3. provisions to encompass your recruitment and interview processes;
  4. details of how you will implement, monitor, evaluate and update the policy;
  5. details of how you will ensure equality in relation to the treatment of employees, managers, clients and third parties instructed in connection with client matters;
  6. details of how complaints and disciplinary issues are to be dealt with;
  7. details of the firm’s arrangements for workforce diversity monitoring; and
  8. details of how the firm will communicate the policy to employees, managers and clients;

IB(7.2). providing employees and managers with training and information about complying with equality and diversity requirements; and

IB(7.3). monitoring and responding to issues identified by your policy and reviewing and updating your policy.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(7.4). being subject to any decision of a court or tribunal of the UK , that you have committed, or are to be treated as having committed, an unlawful act of discrimination; and

IB(7.5). discriminating unlawfully when accepting or refusing instructions to act for a client.

IB(7.6). Acting in accordance with your client’s instructions when doing so would unlawfully discriminate against a protected group (e.g. requesting a celebrant of a particular ethnicity on behalf of your client). 

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(7.1). having a written equality and diversity policy (which may be contained within one or more documents, including one or more policy documents, as appropriate) which is appropriate to the size of the firm and includes the following features:

  1. a commitment to the principles of equality and diversity and legislative requirements;
  2. a requirement that all employees and managers comply with the outcomes;
  3. provisions to encompass your recruitment and interview processes;
  4. details of how you will implement, monitor, evaluate and update the policy;
  5. details of how you will ensure equality in relation to the treatment of employees, managers, clients and third parties instructed in connection with client matters;
  6. details of how complaints and disciplinary issues are to be dealt with;
  7. details of the firm’s arrangements for workforce diversity monitoring; and
  8. details of how the firm will communicate the policy to employees, managers and clients;

IB(7.2). providing employees and managers with training and information about complying with equality and diversity requirements; and

IB(7.3). monitoring and responding to issues identified by your policy and reviewing and updating your policy.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(7.4). being subject to any decision of a court or tribunal of the UK , that you have committed, or are to be treated as having committed, an unlawful act of discrimination; and

IB(7.5). discriminating unlawfully when accepting or refusing instructions to act for a client.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(7.1). having a written equality and diversity policy (which may be contained within one or more documents, including one or more policy documents, as appropriate) which is appropriate to the size of the firm and includes the following features:

  1. a commitment to the principles of equality and diversity and legislative requirements;
  2. a requirement that all employees and managers comply with the outcomes;
  3. provisions to encompass your recruitment and interview processes;
  4. details of how you will implement, monitor, evaluate and update the policy;
  5. details of how you will ensure equality in relation to the treatment of employees, managers, clients and third parties instructed in connection with client matters;
  6. details of how complaints and disciplinary issues are to be dealt with;
  7. details of the firm’s arrangements for workforce diversity monitoring; and
  8. details of how the firm will communicate the policy to employees, managers and clients.

IB(7.2). providing employees and managers with training and information about complying with equality and diversity requirements;

IB(7.3). monitoring and responding to issues identified by your policy and reviewing and updating your policy.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(7.4). being subject to any decision of a court or tribunal of the UK , that you have committed, or are to be treated as having committed, an unlawful act of discrimination;

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(7.1). having a written equality and diversity policy (which may be contained within one or more documents, including one or more policy documents, as appropriate) which is appropriate to the size of the firm and includes the following features:

  1. a commitment to the principles of equality and diversity and legislative requirements;
  2. a requirement that all employees and managers comply with the outcomes;
  3. provisions to encompass your recruitment and interview processes;
  4. details of how you will implement, monitor, evaluate and update the policy;
  5. details of how you will ensure equality in relation to the treatment of employees, managers, clients and third parties instructed in connection with client matters;
  6. details of how complaints and disciplinary issues are to be dealt with;
  7. details of the firm’s arrangements for workforce diversity monitoring; and
  8. details of how the firm will communicate the policy to employees, managers and clients; 

IB(7.3). monitoring and responding to issues identified by your policy and reviewing and updating your policy.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(7.1). having a written equality and diversity policy (which may be contained within one or more documents, including one or more policy documents, as appropriate) which is appropriate to the size of the firm and includes the following features:

  1. a commitment to the principles of equality and diversity and legislative requirements;
  2. a requirement that all employees and managers comply with the outcomes;
  3. provisions to encompass your recruitment and interview processes;
  4. details of how you will implement, monitor, evaluate and update the policy;
  5. details of how you will ensure equality in relation to the treatment of employees, managers, clients and third parties instructed in connection with client matters;
  6. details of how complaints and disciplinary issues are to be dealt with;
  7. details of the firm’s arrangements for workforce diversity monitoring; and
  8. details of how the firm will communicate the policy to employees, managers and clients.

IB(7.2). providing employees and managers with training and information about complying with equality and diversity requirements; and

IB(7.3). monitoring and responding to issues identified by your policy and reviewing and updating your policy.

Full list of Part 7 indicative behaviours

Acting in the following way(s) may tend to show that you have achieved these outcomes and therefore complied with the Principles:

IB(7.1). having a written equality and diversity policy (which may be contained within one or more documents, including one or more policy documents, as appropriate) which is appropriate to the size of the firm and includes the following features:

  1. a commitment to the principles of equality and diversity and legislative requirements;
  2. a requirement that all employees and managers comply with the outcomes;
  3. provisions to encompass your recruitment and interview processes;
  4. details of how you will implement, monitor, evaluate and update the policy;
  5. details of how you will ensure equality in relation to the treatment of employees, managers, clients and third parties instructed in connection with client matters;
  6. details of how complaints and disciplinary issues are to be dealt with;
  7. details of the firm’s arrangements for workforce diversity monitoring; and
  8. details of how the firm will communicate the policy to employees, managers and clients;

IB(7.2). providing employees and managers with training and information about complying with equality and diversity requirements; and

IB(7.3). monitoring and responding to issues identified by your policy and reviewing and updating your policy.

Acting in the following way(s) may tend to show that you have not achieved these outcomes and therefore not complied with the Principles:

IB(7.4). being subject to any decision of a court or tribunal of the UK , that you have committed, or are to be treated as having committed, an unlawful act of discrimination;

IB(7.5). discriminating unlawfully when accepting or refusing instructions to act for a client; and

IB(7.6). Acting in accordance with your client’s instructions when doing so would unlawfully discriminate against a protected group (e.g. requesting a celebrant of a particular ethnicity on behalf of your client). 

Notes

The obligations in this part closely mirror your legal obligations. You can obtain further information from the Equality and Human Rights Commission, www.equalityhumanrights.com.

Part 8: Confidentiality and data protection

This part is about the protection of clients’ confidential information and confidential information relating to the deceased people entrusted into your care.

Protection of confidential information is a fundamental feature of your relationship with clients. It exists as a concept both as a matter of law and as a matter of conduct. This duty continues despite the end of your contractual relationship.

Outcomes

You must achieve these outcomes:

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(8.1). your systems and controls for identifying risks to client confidentiality are appropriate to the size and complexity of your business;

IB(8.2). you comply with the law in respect of your data protection obligations;

IB(8.3). you only outsource services when you are satisfied that the provider has taken all appropriate steps to ensure that your clients’ confidential information will be protected;

IB(8.4). you have a clear General Data Protection Regulation (GDPR) compliance policy and make all clients aware of this; and

IB(8.5). You specifically appoint a data protection compliance officer to monitor your compliance with the GDPR.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(8.6). disclosing information about your client’s instructions to a third party unless consent has been provided by your client for the information to be released.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(8.1). your systems and controls for identifying risks to client confidentiality are appropriate to the size and complexity of your business;

IB(8.2). you comply with the law in respect of your data protection obligations;

IB(8.3). you only outsource services when you are satisfied that the provider has taken all appropriate steps to ensure that your clients’ confidential information will be protected; and

IB(8.4). you have a clear General Data Protection Regulation (GDPR) compliance policy and make all clients aware of this.

Acting in the following way(s) may tend to show that you have not achieved this outcome and therefore not complied with the relevant Principles:

IB(8.6). disclosing information about your client’s instructions to a third party unless consent has been provided by your client for the information to be released.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(8.1). your systems and controls for identifying risks to client confidentiality are appropriate to the size and complexity of your business;

IB(8.2). you comply with the law in respect of your data protection obligations;

IB(8.4). you have a clear General Data Protection Regulation (GDPR) compliance policy and make all clients aware of this; and

IB(8.5). You specifically appoint a data protection compliance officer to monitor your compliance with the GDPR.

Full list of Part 8 indicative behaviours

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(8.1). your systems and controls for identifying risks to client confidentiality are appropriate to the size and complexity of your business; 

IB(8.2). you comply with the law in respect of your data protection obligations;

IB(8.3). you only outsource services when you are satisfied that the provider has taken all appropriate steps to ensure that your clients’ confidential information will be protected;

IB(8.4). you have a clear General Data Protection Regulation (GDPR) compliance policy and make all clients aware of this; and

IB(8.5). You specifically appoint a data protection compliance officer to monitor your compliance with the GDPR.

Acting in the following way(s) may tend to show that you have not achieved these outcomes and therefore not complied with the Principles:

IB(8.6). disclosing information about your client’s instructions to a third party unless consent has been provided by your client for the information to be released.

Notes

The protection of confidential information may be at particular risk where a firm or business changes hands.

Part 9: Complaint handling

This part is about ensuring that if clients are not happy with the service they have received they know how to make a complaint and that all complaints are dealt with promptly and fairly.

Outcomes 

You must achieve these outcomes:

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(9.1). you have a written complaints procedure which:

  1. is brought to clients’ attention at the point of taking first instructions;
  2. is easy for clients to use and understand, allowing for complaints to be made by any reasonable means;
  3. enables complaints to be dealt with promptly and fairly, with decisions based on a sufficient investigation of the circumstances; and
  4. does not involve any charges to clients for handling their complaints;

IB(9.2). you provide printed copies of your complaints procedure upon request;

IB(9.3). in the event that someone makes a complaint, providing them with all necessary information concerning the handling of the complaint;

IB(9.4). clients are informed, both at the time of engagement and at the conclusion of your complaints procedure, of their right to complain to any trade body that you belong to, the time frame for doing so and full details of how to do this; and

IB(9.5). if you are regulated by an external body, you inform clients that services you provide are monitored and regulated by the relevant organisation(s) and how this affects the protections available to them.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(9.1). you have a written complaints procedure which:

  1. is brought to clients’ attention at the point of taking first instructions;
  2. is easy for clients to use and understand, allowing for complaints to be made by any reasonable means;
  3. enables complaints to be dealt with promptly and fairly, with decisions based on a sufficient investigation of the circumstances; and
  4. does not involve any charges to clients for handling their complaints.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(9.1). you have a written complaints procedure which:

  1. is brought to clients’ attention at the point of taking first instructions;
  2. is easy for clients to use and understand, allowing for complaints to be made by any reasonable means;
  3. enables complaints to be dealt with promptly and fairly, with decisions based on a sufficient investigation of the circumstances; and
  4. does not involve any charges to clients for handling their complaints;

IB(9.2). you provide printed copies of your complaints procedure upon request;

IB(9.3). in the event that someone makes a complaint, providing them with all necessary information concerning the handling of the complaint;

IB(9.4). clients are informed, both at the time of engagement and at the conclusion of your complaints procedure, of their right to complain to any trade body that you belong to, the time frame for doing so and full details of how to do this; and

IB(9.5). if you are regulated by an external body, you inform clients that services you provide are monitored and regulated by the relevant organisation(s) and how this affects the protections available to them.

Full list of Part 9 indicative behaviours

Acting in the following way(s) may tend to show that you have achieved these outcomes and therefore complied with the Principles:

IB(9.1). you have a written complaints procedure which:

  1. is brought to clients’ attention at the point of taking first instructions;
  2. is easy for clients to use and understand, allowing for complaints to be made by any reasonable means;
  3. enables complaints to be dealt with promptly and fairly, with decisions based on a sufficient investigation of the circumstances; and
  4. does not involve any charges to clients for handling their complaints;

IB(9.2). you provide printed copies of your complaints procedure upon request;

IB(9.3). in the event that someone makes a complaint, providing them with all necessary information concerning the handling of the complaint;

IB(9.4). clients are informed, both at the time of engagement and at the conclusion of your complaints procedure, of their right to complain to any trade body that you belong to, the time frame for doing so and full details of how to do this; and

IB(9.5). if you are regulated by an external body, you inform clients that services you provide are monitored and regulated by the relevant organisation(s) and how this affects the protections available to them.

Part 10: Working with your regulators

The outcomes in this part show how the Principles apply in the context of you and your regulators.

All references to ‘your regulators’ in this Code should be interpreted as including any trade association you belong to, any future statutory regulator and any other entity seeking to regulate funeral directors in accordance with this Code.

Outcomes

You must achieve these outcomes:

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(10.1). reporting to your regulators any disciplinary action taken against you by another membership body or regulator;

IB(10.2). actively monitoring your achievement of the outcomes in order to improve standards and identify non-achievement of the outcomes.

There are no indicative behaviours to accompany this outcome.

Acting in the following way(s) may tend to show that you have achieved this outcome and therefore complied with the relevant Principles:

IB(10.1). reporting to your regulators any disciplinary action taken against you by another membership body or regulator; and

IB(10.2). actively monitoring your achievement of the outcomes in order to improve standards and identify non-achievement of the outcomes.

Full list of Part 10 indicative behaviours

Acting in the following way(s) may tend to show that you have achieved these outcomes and therefore complied with the Principles:

IB(10.1). reporting to your regulators any disciplinary action taken against you by another membership body or regulator; and

IB(10.2). actively monitoring your achievement of the outcomes in order to improve standards and identify non-achievement of the outcomes.

Glossary

Client The person for whom you act and with whom you have a contractual relationship. This definition is intended to include former clients.
Disbursement Any payment made on behalf of a client to a third party for which reimbursement (without any mark-up) is subsequently charged to the client.
First Offices The process of making a person who has died look presentable for loved ones to view. As a minimum, this will include cleaning and washing the body, dressing them and closing the eyes and mouth.
Funeral Director A person or entity whose business consists of, or includes the arrangement and conduct of funerals.

For the avoidance of doubt, this definition includes all of the following:

  • Funeral business owners
  • Funeral business staff who routinely come into direct contact with bereaved families
  • Funeral business staff responsible for arranging funerals
  • Funeral business staff responsible for the care or transport of deceased people
  • Managers of funeral business staff
  • Funeral business managers
Invasive procedure Any care procedure that involves the breaking of skin or the opening of bodily cavities.
Introducer Means any person, business or organisation who or that introduces or refers clients to your business, or recommends your business to clients or otherwise puts you and clients in touch with each other. This definition is intended to include market comparison websites.
Prospective Client Any member of the public.
Regulator Any trade association you belong to, any future statutory regulator and any other entity appointed to regulate funeral directors in accordance with this Code.