Another day, another Black Lives Matter protest. Another day, another testimony by a black figure in the industry about all the direct and systemic racism they have faced working in the industry. Another day, another statement by a British broadcaster about how it is responding to the current crisis.

When I was first approached by Television to write this piece, the brief was simple: go through recent events, assess the different policy initiatives the industry has announced and offer a prediction as to whether this would lead to lasting change.

And so I started to do just that.

On 8 June, Sky announced a £30m racial injustice fund over the next three years. It will create a diversity action group and invest in programmes that highlight racial injustice. And it will redouble its efforts to increase black, Asian and minority ethnic (BAME) representation both on-screen and behind the camera.

A day later, Channel 4 announced its commitment to be an “anti-racist” organisation, setting out a six-point plan to “be a driver of anti-racism in the industry and improve black and minority ethnic representation”.

The broadcaster reaffirmed previous diversity commitments as well as adding a few new ones, such as doubling “the number of BAME-led independent producers that we commission from by 2023” and launching “a new mentoring programme for our diverse staff in 2020”.

Two weeks later, on 22 June, the BBC caused a minor earthquake, in the way only the BBC can, by announcing it would commit “£100m of its content spend on diverse productions and talent” over the next three years.

I have highlighted three of the bigger announcements of the past few weeks but they are far from isolated cases. Bafta is consulting on how it can address failings around race (my words not theirs). Netflix has a new “Black Lives Matter” category. And there are a host of additional initiatives and programming by other broadcasters and industry stakeholders.

This has all happened against a background of almost daily examples of black people working in the industry giving public accounts of their experiences.

'For black and brown people, the UK media industry is a toxic place to work’

These include Oscar-winning director Steve McQueen calling out parts of the British film industry for “its blatant racism”, accusations of racism on the set of Channel 4’s Hollyoaks and thousands of media professionals signing an open letter addressed to the UK’s major broadcasters calling for substantial changes to “reshape our industry into one whose words are supported by action”.

It would be possible to go through each announcement made by every broadcaster and dissect whether it will really lead to substantial long-term change. Or go through each statement by a high-profile person of colour in the industry and ask, “what do they really mean” and what will be the repercussions of the statements? But, for me, that is missing the far larger and more important picture.

Taken collectively, what has come to the surface in recent weeks is the acknowledgement that, for black and brown people, the UK media industry is a toxic place to work.

Privately, black and brown people have thought this for decades (for as long as I have worked in the industry) and the research bears this out.

According to The Looking Glass report – commissioned by The Film and TV Charity and conducted by Lancaster University Management School – black African, Caribbean or black British men are almost 40% more likely to have been bullied in comparison to men overall working in the industry.

The same report said: “BAME women are most likely to report that their ability to speak out about working practices or the working environment was negatively affecting their well­being”. And, possibly most importantly of all, “three-quarters of mid-career BAME women have contemplated a career change to protect their wellbeing”.

To their credit, the broadcasters seem to be implicitly and explicitly acknowledging the scale of the problem and have not defensively tried to counter the testimony of black and brown people working in the media.

They are at least talking about ­policies that may address some of these issues.

But the bigger question must be: how could an industry toxic for non-white people have been allowed to be created and sustained for so long? And to answer that question we must look beyond the broadcasters’ individual statements and new policy initiatives and look at who regulates the industry.

‘How did the industry regulator not spot this huge issue in the industry?’

If there is a long-term, systemic problem across the entire sector we must ask ourselves what has the industry regulator, Ofcom, been doing over the past two decades or, in the case of the BBC, the BBC Trust and then Ofcom?

When an entire industry seems to be suffering from an issue it is not good enough to simply ask whether Channel 4 will be successful in implementing its anti-racist policy. Or whether the BBC will be able to start doing a better job with its £100m commitment.

It is the very reason we have an industry regulator – to solve industry wide-issues and for it to put conditions within the broadcasters’ licences to rectify market failures.

Interestingly, as far as I can tell, Ofcom is one of the few major industry stakeholders that has not commented on the racial issues that are currently raging through the very industry it regulates.

The obvious question is: how did the industry regulator not spot this huge issue in the industry? Or, to the extent that it did, why did it fail to put sufficient conditions within licence agreements to make sure the issue was addressed to a satisfactory degree?

The answer lies in the structure of Ofcom. The regulator has several advisory boards and subcommittees to represent different groups, raise important issues and give Ofcom focus and direction.

There is the Content Board, which represents the “interest of the viewer, the listener and citizen”. There is a Consumer Panel to “maintain effective arrangements for consultation with consumers”. And there are four advisory boards to represent “interests and opinions” specific to people living in the four UK nations.

The nations’ boards are crucial to “provide specific advice… on matters relating to television, radio and other content on services regulated by Ofcom” in the respective nations they represent.

Despite the UK’s BAME population accounting for 14% of the entire population and therefore being roughly the same size as all the nations outside of England combined (16%), there is no board dedicated to the interests of the country’s ethnic minority communities.

Recent events have surely proved that Ofcom has failed, since its inception in 2003, to give sufficient attention to the task of policing the industry when it comes to ethnic diversity. When four different chairs (and innumerable changes in personnel) over nearly two decades have failed at a specific task it is naive to attribute this to one person’s failings. We must look instead at structural solutions.

The time has surely come for a new board to be established on the same level as the four nations, with the specific remit of looking at the issue of diversity in general and the BAME communities in particular.

To use the Latin phrase Quis custodiet ipsos custodes? (Who guards the guards?): if we want the regulators to do a better job at making sure our industry is a better place for all of us to work, we need to look at the diversity of those advising, overseeing and even judging them.

We have a unique opportunity to change the industry we all love. And that means we cannot just look at the broadcasters.

We must look at the regulators who should have ensured we never reached this position.

Marcus Ryder is the Acting Chair of the Sir Lenny Henry Centre for Media Diversity and an executive producer at Chinese financial media group Caixin Global Media.

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