The Funeral Director Code guides the actions, behaviour and standards of NAFD funeral home and supplier members. It is designed to help those in funeral service to act in the public interest and aspire to the highest professional standards.
The Funeral Director Code guides the actions, behaviour and standards of NAFD funeral home and supplier members. It is designed to help those in funeral service to act in the public interest and aspire to the highest professional standards.
This is not a statutory Code. In the event of conflict between any statutory code of practice or legislation (including the health and safety legislation) and this Code, the applicable legislation/statutory code shall prevail.
The Principles apply to Category A and Category B members of the National Association of Funeral Directors.
The Code Outcomes apply only to Category A members of the National Association of Funeral Directors.
The Code Principles define the fundamental ethical and professional standards expected of NAFD members when providing funeral services. NAFD members and staff should always have regard to the Principles and use them as the 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 describe what NAFD members 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 these mandatory provisions will constitute a breach of this Code. However, not every breach of the Code will result in disciplinary action.
There may be multiple ways of achieving the Outcomes. If you choose a different method from those set out in the NAFD Funeral Director Code Guidance (this can be accessed via the NAFD website), 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.
The outcomes are supplemented by non-mandatory 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 National Association of Funeral Directors (NAFD) is the largest and most inclusive representative body for the UK funeral profession. We support our members to deliver high standards of care for those who have died and we offer bereaved people the information and assurance to help them choose a compassionate, professional and experienced funeral director that they can trust.
Representing the entire spectrum of funeral directing businesses, including independent and family-owned firms, co-operatives and major funeral groups, NAFD has more than 4,100 UK funeral homes in membership, as well as international firms and suppliers to the sector. We provide our members with advice, education services and guidance, empowering them to meet the highest professional standards.
The NAFD sets those high standards and member firms must abide by the NAFD Funeral Director Code. The code is comprehensive, and outcomes focussed, developed in consultation with the funeral sector and consumer organisations. Funeral home members are regularly inspected by our Standards and Quality Management team, assessed and supported to reach the highest standards of service. We also provide access to an independent complaints scheme for funeral consumers, NAFD Resolve, which is operated on our behalf by the Centre for Effective Dispute Resolution (CEDR).
These measures are part of the NAFD’s wider Quality Assurance Framework. The framework supports the mandatory outcomes of the code and allows for greater transparency in the quality guarantee offered to consumers – regardless of the business model or size of the funeral provider. Our code is not prescriptive in behaviours, only in outcomes. For members, this allows flexibility to deliver truly customer responsive services that meet and exceed expectations. The code supports innovative practice and continuous improvement, ultimately providing the public with reassurance that funeral services will always be delivered to agreed standards of quality and transparency.
This Code is founded on the following eleven mandatory principles. Any failure to operate in accordance with these principles will constitute a breach of this Code.
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 of this Code).
You must achieve these outcomes:
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;
Any estimates you provide state clearly which costs are attributable to you and which costs will be paid to a third party on the client’s behalf. Third parties are named wherever possible;
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;
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;
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;
You clearly explain your fees to your client;
You explain in advance about any other payments for which the client may be responsible;
You discuss how the client will pay, including whether state financial support may be available;
You provide information in a clear and accessible form which is appropriate to the needs and circumstances of the client;
You ensure that disbursements included in your bill reflect the actual amount spent or to be spent on behalf of the client.
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.
You must achieve these outcomes:
You carry out annual assessments of your refrigeration capacity requirements to help ensure you can make adequate provision for the year ahead;
You never take more deceased people into your care than you can accommodate in suitable refrigerated spaces; and
You have access to mortuary equipment that can accommodate a wide-range of body types.
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.
You must achieve these outcomes:
You ensure all deceased people in your care are appropriately clothed or covered when not being actively cared for;
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);
You use an appropriate headblock to support the heads of all deceased people stored in your mortuary facility; and
You use a newly cleaned and disinfected tray for each deceased person you store in your mortuary facility.
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.
You must achieve these outcomes:
You ensure every member of staff is informed in writing of the identity of their line manager.
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.
You must achieve these outcomes:
Where you and another business jointly market services, the nature of the services provided by each business is clear.
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.
You must achieve these outcomes:
Staff or subcontractor adhere to a set of defined trade standards, such as the Funeral Celebrant Accord (Funeral Celebrancy Council)
Your complaint procedure includes the ability to complain about the services of a third party subcontractor.
You and your/their staff keep a personal development record and take responsibility for your continued learning.
You require your/their staff to keep up to date with industry developments and devote time every month to their continued personal development.
You regularly review the training needs of your staff and invest in appropriate training and/or qualifications, relevant to the role undertaken.
You ensure DBS checks are carried out for all staff caring for deceased people, bereaved people and those with responsibility for ensuring compliance with legal and conduct obligations.
You have Service Level Agreements (SLA) in place for all third party contracted services, either customer based, service based, or multi-level as appropriate.
This part is about encouraging equality of opportunity and respect for diversity, and preventing unlawful discrimination, in your relationship with your clients and others. It is not intended to cover situations that arise between employers and employees.
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.
You must achieve these outcomes:
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 clients 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, 8. details of how the firm will communicate the policy to employees, managers and clients.
Providing employees and managers with training and information about complying with equality and diversity requirements; and
Monitoring and responding to issues identified by your policy and reviewing and updating your policy.
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.
You must achieve these outcomes:
Your systems and controls for identifying risks to client confidentiality are appropriate to the size and complexity of your business;
You comply with the law in respect of your data protection obligations;
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;
You have a clear General Data Protection Regulation (GDPR) compliance policy and make all clients aware of this; and
You specifically appoint a data protection compliance officer to monitor your compliance with the GDPR.
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.
You must achieve these outcomes:
You inform the client of their rights to complain, including their right to complain about services or invoicing.
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;
4. does not involve any charges to clients for handling their complaints;
In the event that someone makes a complaint, providing them with all necessary information concerning the handling of the complaint;
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
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.
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 the National Association of Funeral Directors and any future statutory regulator.
You must achieve these outcomes:
Reporting to your regulators any disciplinary action taken against you by another membership body or regulator;
Actively monitoring your achievement of the outcomes in order to improve standards and identify non-achievement of the outcomes.
Part 1: Caring for your clients
Part 2: Your operational facilities
Part 3: Caring for deceased people
Part 4: Management of your business
Part 5: Publicity and the ethical procurement of business
Part 6: Training and professional development
Part 7: Equality and diversity
Part 8: Confidentiality and data protection
The person for whom you act and with whom you have a contractual relationship. This definition is intended to include former clients.
Any payment made on behalf of a client to a third party for which reimbursement (without mark-up) is subsequently charged to the client.
The process of making a person who has died look presentable. As a minimum, this will include cleaning and washing the body, dressing the deceased and closing the eyes. Closing of the mouth may also be carried out, where appropriate.
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:
Any care procedure that involves the breaking of skin or the opening of bodily cavities, including embalming.
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.
Any member of the public.
The National Association of Funeral Directors, any future statutory regulator and any other entity appointed to regulate funeral directors in accordance with this Code.
Any contact with a customer or potential customer that involves unlawful data processing or for which the individual has not provided prior consent. For the avoidance of doubt, advertising and leaflet dropping are not covered by this definition.
Exercising care to avoid harm to other persons or their property. Reasonable steps taken to avoid committing an offence.
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