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GOVERNANCE

Governance Framework

Towerblock Radio CIC's governance framework provides the structure, policies and controls that ensure the organisation is run responsibly, transparently and in the best interests of the community it serves. This framework is designed to meet the standards expected by the National Lottery Community Fund, Arts Council England, Youth Music, Heritage Lottery Fund, local authorities, trusts, foundations and corporate sponsors.

Mission

Towerblock Radio CIC exists to support underground music culture, provide a platform for artists and DJs, deliver community workshops and youth engagement, preserve music heritage, and create genuine opportunities for communities through broadcasting, events, training and creative arts.

Legal Structure

Towerblock Radio is constituted as a Community Interest Company (CIC) limited by guarantee, registered at Companies House and regulated by the CIC Regulator. The CIC structure ensures that assets and surpluses are used for the community interest, enforced through the asset lock.

Governance Structure

The organisation is governed by a board of directors who are legally responsible for the organisation under the Companies Act 2006 and CIC Regulations. The board sets strategy, approves policies, ensures compliance, and delegates operational authority to staff leads and volunteers.

Board Responsibilities

The board is collectively responsible for setting the mission and strategic direction, ensuring legal compliance, approving budgets and accounts, managing risk, ensuring safeguarding, approving major funding and partnerships, and reviewing policy. See the Board Governance Policy and Director Responsibilities.

Delegated Authority

The board delegates operational decisions to staff leads and volunteers through the Delegated Authority Policy and Financial Delegation Matrix, ensuring no single person can commit significant funds without oversight.

Financial Governance

Financial governance is maintained through the Finance Controls Policy, Financial Delegation Matrix, Internal Controls Policy, Fraud Prevention Policy, Reserves Policy, Procurement Policy, and annual independent review. Restricted funds are managed in accordance with the Restricted Funds Policy and Grant Management Policy.

Safeguarding Framework

The safeguarding framework comprises the Safeguarding Policy, Adult Safeguarding Policy, Safer Recruitment Policy, DBS Policy, and safeguarding procedures embedded across all operational policies. A Safeguarding Lead oversees implementation.

Risk Framework

Risk is managed through the Risk Management Policy and Risk Register, reviewed at every board meeting. The Business Continuity Plan and Disaster Recovery Policy ensure operational resilience.

Compliance Framework

Towerblock Radio CIC complies with the Companies Act 2006, CIC Regulations 2005, UK GDPR, Equality Act 2010, Health and Safety at Work etc. Act 1974, Safeguarding Vulnerable Groups Act 2006, Care Act 2014, Bribery Act 2010, Copyright Designs and Patents Act 1988, and the Ofcom Broadcasting Code where applicable. The Charity Governance Code is followed as best practice.

Annual Review Schedule

All policies are reviewed annually. The board conducts an annual policy review, risk workshop, skills audit, safeguarding review, financial review, and compliance audit. The annual review cycle runs from July to July.

Compliance Calendar

Key annual deadlines: CIC Report and accounts filed with Companies House (within 9 months of year end), confirmation statement filed annually, PRS and PPL licence renewals, DBS check renewals (every 3 years), policy reviews (annually), risk register review (each board meeting), and insurance renewals.

Document Control

All policies are version-controlled, approved by the board, and published on the website. Superseded versions are retained for six years. The Policy Library below provides the complete reference.

Policy Library

Safeguarding Policy

For children, young people, workshops, mentoring, volunteers and community activity.

https://towerblock.radio/policies/safeguarding

Adult Safeguarding Policy

For adults at risk, volunteers, artists, visitors and community participants.

https://towerblock.radio/policies/adult-safeguarding

Equality, Diversity and Inclusion Policy

Our commitment to fair access, anti discrimination and inclusive music culture.

https://towerblock.radio/policies/equality-diversity-inclusion

Volunteer Policy

How volunteers are recruited, supported, trained and treated.

https://towerblock.radio/policies/volunteer

Complaints Policy

How concerns, complaints and feedback can be raised and handled.

https://towerblock.radio/policies/complaints

Data Protection / Privacy Policy

How Tower Block Radio collects, uses, stores and protects personal information.

https://towerblock.radio/policies/privacy

Health and Safety Policy

How we manage safety for events, workshops, studios, volunteers and community activity.

https://towerblock.radio/policies/health-and-safety

Risk Assessment Template

A practical template for workshops, live broadcasts, events and volunteer activity.

https://towerblock.radio/policies/risk-assessment-template

Code of Conduct for DJs

Standards for DJs, hosts, presenters, guests and show contributors.

https://towerblock.radio/policies/dj-code-of-conduct

Music Submission Terms

Rules for submitting tracks, promos, dubplates, unreleased music and artist material.

https://towerblock.radio/policies/music-submission-terms

Rights / Takedown Policy

How rights holders can request removal, correction, credit or review of content.

https://towerblock.radio/policies/rights-takedown

Finance Controls Policy

How income, grants, donations, spending and approvals should be managed.

https://towerblock.radio/policies/finance-controls

Expenses Policy

How approved volunteers, staff, contractors or contributors can claim expenses.

https://towerblock.radio/policies/expenses

Board Governance Policy

How the board governs Towerblock Radio CIC, including meetings, quorum and director duties.

https://towerblock.radio/policies/board-governance

Conflict of Interest Policy

How conflicts of interest are declared, managed and recorded.

https://towerblock.radio/policies/conflict-of-interest

Register of Interests

The formal register of financial, personal and family interests declared by directors.

https://towerblock.radio/policies/register-of-interests

Delegated Authority Policy

How decision-making is delegated from the board to staff and volunteers, with clear limits.

https://towerblock.radio/policies/delegated-authority

Financial Delegation Matrix

Spending approval limits for directors, staff and volunteers, ensuring dual authorisation.

https://towerblock.radio/policies/financial-delegation-matrix

Grant Management Policy

How grants are managed from application through to delivery, reporting and closure.

https://towerblock.radio/policies/grant-management

Grant Acceptance Policy

Criteria and process for reviewing and accepting grant offers.

https://towerblock.radio/policies/grant-acceptance

Procurement Policy

Competitive quoting, tendering and supplier selection for all purchasing decisions.

https://towerblock.radio/policies/procurement

Fraud Prevention Policy

How we prevent, detect and respond to fraud, theft and financial misconduct.

https://towerblock.radio/policies/fraud-prevention

Anti-Bribery and Corruption Policy

Compliance with the Bribery Act 2010, prohibiting all forms of bribery and corruption.

https://towerblock.radio/policies/anti-bribery-corruption

Gifts and Hospitality Policy

How gifts and hospitality are accepted, given, declared and registered.

https://towerblock.radio/policies/gifts-hospitality

Reserves Policy

How reserves are built, maintained and used to ensure financial sustainability.

https://towerblock.radio/policies/reserves

Investment Policy

How surplus funds are invested ethically and prudently.

https://towerblock.radio/policies/investment

Asset Management Policy

How physical and digital assets are recorded, maintained and protected.

https://towerblock.radio/policies/asset-management

Business Continuity Plan

How we maintain essential services during a disruption.

https://towerblock.radio/policies/business-continuity-plan

Disaster Recovery Policy

How IT systems, data and broadcast infrastructure are restored after a major incident.

https://towerblock.radio/policies/disaster-recovery

Document Retention Policy

How long documents and records are kept, and how they are securely destroyed.

https://towerblock.radio/policies/document-retention

Information Security Policy

How information assets are protected from unauthorised access and breaches.

https://towerblock.radio/policies/information-security

Cyber Security Policy

How digital systems, networks and data are protected from cyber threats.

https://towerblock.radio/policies/cyber-security

Risk Management Policy

How risks are identified, assessed, managed and monitored across the organisation.

https://towerblock.radio/policies/risk-management

Risk Register

The formal register of identified risks, assessments and mitigation controls.

https://towerblock.radio/policies/risk-register

Internal Controls Policy

The controls framework ensuring financial accuracy and fraud prevention.

https://towerblock.radio/policies/internal-controls

Whistleblowing Policy

A safe, confidential route to raise concerns about wrongdoing or malpractice.

https://towerblock.radio/policies/whistleblowing

Recruitment Policy

How staff and volunteers are recruited fairly and transparently.

https://towerblock.radio/policies/recruitment

Safer Recruitment Policy

Safer recruitment practices to protect children and adults at risk.

https://towerblock.radio/policies/safer-recruitment

DBS Policy

How Disclosure and Barring Service checks are obtained, handled and stored.

https://towerblock.radio/policies/dbs

Staff Handbook

Essential information about the organisation, expectations and policies.

https://towerblock.radio/policies/staff-handbook

Director Responsibilities

The legal duties of directors under the Companies Act 2006 and CIC Regulations.

https://towerblock.radio/policies/director-responsibilities

Director Code of Conduct

Behavioural standards expected from directors beyond legal duties.

https://towerblock.radio/policies/director-code-of-conduct

Equality Monitoring Statement

How we collect and use diversity data to improve inclusion.

https://towerblock.radio/policies/equality-monitoring-statement

Anti-Harassment Policy

Our zero-tolerance approach to harassment and how we respond.

https://towerblock.radio/policies/anti-harassment

Bullying Policy

Our zero-tolerance approach to bullying and how we respond.

https://towerblock.radio/policies/bullying

Lone Working Policy

How we manage risks for staff and volunteers who work alone.

https://towerblock.radio/policies/lone-working

Mental Health and Wellbeing Policy

How we support the mental health and wellbeing of staff and volunteers.

https://towerblock.radio/policies/mental-health-wellbeing

Volunteer Agreement

Mutual expectations between Towerblock Radio CIC and its volunteers.

https://towerblock.radio/policies/volunteer-agreement

Editorial Standards Policy

The editorial standards governing all content produced and broadcast.

https://towerblock.radio/policies/editorial-standards

Live Broadcast Policy

Standards and procedures for live broadcasting.

https://towerblock.radio/policies/live-broadcast

Presenter Agreement

Terms and expectations for presenters, DJs and show hosts.

https://towerblock.radio/policies/presenter-agreement

Guest Contributor Policy

Standards and procedures for guest contributors.

https://towerblock.radio/policies/guest-contributor

Studio Rules

Rules for using the studio, including access, conduct and equipment.

https://towerblock.radio/policies/studio-rules

Broadcast Complaints Procedure

How complaints about broadcast content are handled.

https://towerblock.radio/policies/broadcast-complaints-procedure

Copyright Compliance Policy

How we ensure compliance with copyright law in all activities.

https://towerblock.radio/policies/copyright-compliance

Playlist and Music Compliance Policy

How playlists and music selection are managed for compliance.

https://towerblock.radio/policies/playlist-music-compliance

Recording and Archive Policy

How broadcast recordings are recorded, stored and managed.

https://towerblock.radio/policies/recording-archive

Podcast Policy

How podcasts are produced, published and managed.

https://towerblock.radio/policies/podcast

AI Generated Content Policy

How AI-generated content is used, managed and disclosed.

https://towerblock.radio/policies/ai-generated-content

Community Moderation Policy

How online community spaces are moderated for safety.

https://towerblock.radio/policies/community-moderation

Social Media Policy

How social media is used across all platforms.

https://towerblock.radio/policies/social-media

Accessibility Policy

Our commitment to accessibility across all activities.

https://towerblock.radio/policies/accessibility

Environmental Policy

How we reduce our environmental impact.

https://towerblock.radio/policies/environmental

Sustainability Policy

Our commitment to long-term organisational, financial and social sustainability.

https://towerblock.radio/policies/sustainability

Event Safety Policy

How safety is managed at events, workshops and outside broadcasts.

https://towerblock.radio/policies/event-safety

Incident Reporting Procedure

How incidents are reported, investigated and learned from.

https://towerblock.radio/policies/incident-reporting-procedure

Accident Reporting Procedure

How accidents are reported and recorded, including RIDDOR reporting.

https://towerblock.radio/policies/accident-reporting-procedure

Fire Safety Procedure

How fire safety is managed in premises and at events.

https://towerblock.radio/policies/fire-safety-procedure

First Aid Procedure

How first aid is managed in premises and at events.

https://towerblock.radio/policies/first-aid-procedure

Equipment Loan Policy

How equipment loans to staff, volunteers and DJs are managed.

https://towerblock.radio/policies/equipment-loan

Key Holder Policy

How keys and access to premises are managed securely.

https://towerblock.radio/policies/key-holder

Visitor Policy

How visitors to premises are managed safely and securely.

https://towerblock.radio/policies/visitor

Cookie Policy

How cookies are used on the website, and your choices.

https://towerblock.radio/policies/cookie

Website Terms of Use

The rules for using the Towerblock Radio website.

https://towerblock.radio/policies/website-terms-of-use

Acceptable Use Policy

Rules for using IT systems, networks and digital services.

https://towerblock.radio/policies/acceptable-use

Community Guidelines

Standards of behaviour expected in our online community spaces.

https://towerblock.radio/policies/community-guidelines

Member Terms

The conditions for Towerblock Radio CIC membership.

https://towerblock.radio/policies/member-terms

Virtual Membership Terms

Conditions for online-only membership, digital access and content.

https://towerblock.radio/policies/virtual-membership-terms

Funding Acceptance Policy

Criteria and process for accepting funding from any source.

https://towerblock.radio/policies/funding-acceptance

Restricted Funds Policy

How restricted funds are managed, tracked and reported.

https://towerblock.radio/policies/restricted-funds

Donor Acceptance Policy

Criteria and process for accepting donations.

https://towerblock.radio/policies/donor-acceptance

Sponsorship and Partnership Policy

How sponsorship and partnership relationships are managed ethically.

https://towerblock.radio/policies/sponsorship-partnership

Fundraising Ethics Policy

The ethical principles governing all fundraising activity.

https://towerblock.radio/policies/fundraising-ethics

Governance Matrix

Every policy, its owner, review frequency, legal basis and status.

PolicyOwnerReviewLegal RequirementFunding RequirementURLStatus
Safeguarding PolicySafeguarding LeadAnnualYesYes/policies/safeguardingExisting
Adult Safeguarding PolicySafeguarding LeadAnnualYesYes/policies/adult-safeguardingExisting
Equality, Diversity and Inclusion PolicyCommunity LeadAnnualYesYes/policies/equality-diversity-inclusionExisting
Volunteer PolicyVolunteer CoordinatorAnnualYesYes/policies/volunteerExisting
Complaints PolicyOperations LeadAnnualYesYes/policies/complaintsExisting
Data Protection / Privacy PolicyData Protection ContactAnnualYesYes/policies/privacyExisting
Health and Safety PolicyOperations LeadAnnualYesYes/policies/health-and-safetyExisting
Risk Assessment TemplateOperations LeadAnnualYesYes/policies/risk-assessment-templateExisting
Code of Conduct for DJsProgramming LeadAnnualYesYes/policies/dj-code-of-conductExisting
Music Submission TermsMusic Submissions LeadAnnualYesYes/policies/music-submission-termsExisting
Rights / Takedown PolicyRights ContactAnnualYesYes/policies/rights-takedownExisting
Finance Controls PolicyFinance LeadAnnualYesYes/policies/finance-controlsExisting
Expenses PolicyFinance LeadAnnualYesYes/policies/expensesExisting
Board Governance PolicyBoard ChairAnnualBest practiceYes/policies/board-governanceNew
Conflict of Interest PolicyBoard ChairAnnualBest practiceYes/policies/conflict-of-interestNew
Register of InterestsBoard ChairAnnualBest practiceYes/policies/register-of-interestsNew
Delegated Authority PolicyBoard ChairAnnualBest practiceYes/policies/delegated-authorityNew
Financial Delegation MatrixFinance LeadAnnualBest practiceYes/policies/financial-delegation-matrixNew
Grant Management PolicyFinance LeadAnnualBest practiceYes/policies/grant-managementNew
Grant Acceptance PolicyBoard ChairAnnualBest practiceYes/policies/grant-acceptanceNew
Procurement PolicyFinance LeadAnnualBest practiceYes/policies/procurementNew
Fraud Prevention PolicyFinance LeadAnnualBest practiceYes/policies/fraud-preventionNew
Anti-Bribery and Corruption PolicyBoard ChairAnnualBest practiceYes/policies/anti-bribery-corruptionNew
Gifts and Hospitality PolicyBoard ChairAnnualBest practiceYes/policies/gifts-hospitalityNew
Reserves PolicyFinance LeadAnnualBest practiceYes/policies/reservesNew
Investment PolicyFinance LeadAnnualBest practiceYes/policies/investmentNew
Asset Management PolicyOperations LeadAnnualBest practiceYes/policies/asset-managementNew
Business Continuity PlanOperations LeadAnnualBest practiceYes/policies/business-continuity-planNew
Disaster Recovery PolicyOperations LeadAnnualBest practiceYes/policies/disaster-recoveryNew
Document Retention PolicyData Protection ContactAnnualBest practiceYes/policies/document-retentionNew
Information Security PolicyData Protection ContactAnnualBest practiceYes/policies/information-securityNew
Cyber Security PolicyOperations LeadAnnualBest practiceYes/policies/cyber-securityNew
Risk Management PolicyBoard ChairAnnualBest practiceYes/policies/risk-managementNew
Risk RegisterBoard ChairAnnualBest practiceYes/policies/risk-registerNew
Internal Controls PolicyFinance LeadAnnualBest practiceYes/policies/internal-controlsNew
Whistleblowing PolicyBoard ChairAnnualBest practiceYes/policies/whistleblowingNew
Recruitment PolicyOperations LeadAnnualBest practiceYes/policies/recruitmentNew
Safer Recruitment PolicySafeguarding LeadAnnualBest practiceYes/policies/safer-recruitmentNew
DBS PolicySafeguarding LeadAnnualBest practiceYes/policies/dbsNew
Staff HandbookOperations LeadAnnualBest practiceYes/policies/staff-handbookNew
Director ResponsibilitiesBoard ChairAnnualBest practiceYes/policies/director-responsibilitiesNew
Director Code of ConductBoard ChairAnnualBest practiceYes/policies/director-code-of-conductNew
Equality Monitoring StatementOperations LeadAnnualBest practiceYes/policies/equality-monitoring-statementNew
Anti-Harassment PolicyOperations LeadAnnualBest practiceYes/policies/anti-harassmentNew
Bullying PolicyOperations LeadAnnualBest practiceYes/policies/bullyingNew
Lone Working PolicyOperations LeadAnnualBest practiceYes/policies/lone-workingNew
Mental Health and Wellbeing PolicyOperations LeadAnnualBest practiceYes/policies/mental-health-wellbeingNew
Volunteer AgreementVolunteer CoordinatorAnnualBest practiceYes/policies/volunteer-agreementNew
Editorial Standards PolicyProgramming LeadAnnualBest practiceYes/policies/editorial-standardsNew
Live Broadcast PolicyProgramming LeadAnnualBest practiceYes/policies/live-broadcastNew
Presenter AgreementProgramming LeadAnnualBest practiceYes/policies/presenter-agreementNew
Guest Contributor PolicyProgramming LeadAnnualBest practiceYes/policies/guest-contributorNew
Studio RulesOperations LeadAnnualBest practiceYes/policies/studio-rulesNew
Broadcast Complaints ProcedureProgramming LeadAnnualBest practiceYes/policies/broadcast-complaints-procedureNew
Copyright Compliance PolicyRights ContactAnnualBest practiceYes/policies/copyright-complianceNew
Playlist and Music Compliance PolicyProgramming LeadAnnualBest practiceYes/policies/playlist-music-complianceNew
Recording and Archive PolicyProgramming LeadAnnualBest practiceYes/policies/recording-archiveNew
Podcast PolicyProgramming LeadAnnualBest practiceYes/policies/podcastNew
AI Generated Content PolicyProgramming LeadAnnualBest practiceYes/policies/ai-generated-contentNew
Community Moderation PolicyOperations LeadAnnualBest practiceYes/policies/community-moderationNew
Social Media PolicyCommunications LeadAnnualBest practiceYes/policies/social-mediaNew
Accessibility PolicyOperations LeadAnnualBest practiceYes/policies/accessibilityNew
Environmental PolicyOperations LeadAnnualBest practiceYes/policies/environmentalNew
Sustainability PolicyBoard ChairAnnualBest practiceYes/policies/sustainabilityNew
Event Safety PolicyOperations LeadAnnualBest practiceYes/policies/event-safetyNew
Incident Reporting ProcedureOperations LeadAnnualBest practiceYes/policies/incident-reporting-procedureNew
Accident Reporting ProcedureOperations LeadAnnualBest practiceYes/policies/accident-reporting-procedureNew
Fire Safety ProcedureOperations LeadAnnualBest practiceYes/policies/fire-safety-procedureNew
First Aid ProcedureOperations LeadAnnualBest practiceYes/policies/first-aid-procedureNew
Equipment Loan PolicyOperations LeadAnnualBest practiceYes/policies/equipment-loanNew
Key Holder PolicyOperations LeadAnnualBest practiceYes/policies/key-holderNew
Visitor PolicyOperations LeadAnnualBest practiceYes/policies/visitorNew
Cookie PolicyData Protection ContactAnnualBest practiceYes/policies/cookieNew
Website Terms of UseOperations LeadAnnualBest practiceYes/policies/website-terms-of-useNew
Acceptable Use PolicyOperations LeadAnnualBest practiceYes/policies/acceptable-useNew
Community GuidelinesOperations LeadAnnualBest practiceYes/policies/community-guidelinesNew
Member TermsOperations LeadAnnualBest practiceYes/policies/member-termsNew
Virtual Membership TermsOperations LeadAnnualBest practiceYes/policies/virtual-membership-termsNew
Funding Acceptance PolicyBoard ChairAnnualBest practiceYes/policies/funding-acceptanceNew
Restricted Funds PolicyFinance LeadAnnualBest practiceYes/policies/restricted-fundsNew
Donor Acceptance PolicyBoard ChairAnnualBest practiceYes/policies/donor-acceptanceNew
Sponsorship and Partnership PolicyBoard ChairAnnualBest practiceYes/policies/sponsorship-partnershipNew
Fundraising Ethics PolicyBoard ChairAnnualBest practiceYes/policies/fundraising-ethicsNew

Policy Dependency Map

Every policy links to the policies it depends on and the policies it informs. No policy restates another's content — instead, relationships are defined here as a single source of truth, preventing overlap and ensuring updates propagate correctly.

Governance

Risk Register1 deps · 1 informed

Depends on: Risk Management Policy

Informs: Board Governance Policy

People

Broadcasting

Operations

Environmental Policy1 deps · 1 informed

Depends on: Sustainability Policy

Informs: Procurement Policy

Compliance Gap Analysis

Already Complete (13 policies)

Safeguarding, Adult Safeguarding, EDI, Volunteer, Complaints, Privacy, Health and Safety, Risk Assessment Template, DJ Code of Conduct, Music Submission Terms, Rights/Takedown, Finance Controls, Expenses. These existing policies cover core operational and safeguarding requirements and are suitable for inclusion in funding applications. Recommended amendments: add version numbers, formal approval sections, and cross-references to new policies.

Needs Updating (13 policies)

All 13 existing policies need minor amendments to align with the new governance framework: adding formal version numbers, approval sections, review dates, related policies cross-references, and website URL slugs as specified in Task 3. The existing content is substantive and does not need to be rewritten.

Missing — Now Created (62 policies)

62 new policies have been created across six categories: Governance (22), People (13), Broadcasting (13), Operations (11), Digital (6), and Funding (5). These cover all the governance documents identified as missing in the audit, including board governance, financial controls, safeguarding, broadcasting standards, operational safety, digital compliance and funding ethics.

Recommended Future Policies

As the organisation grows: Data Processing Agreement template, Staff Privacy Notice, Privacy Impact Assessment template, Articles of Association summary, Memorandum of Understanding template for partners, Sponsorship Agreement template, DJ Contract template, Workshop Risk Assessment register, Annual Report template, and Trustee Recruitment Pack.

Current broadcast artwork

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