stakeholder groups

TCWG are responsible for the entity's strategic direction and accountability including overseeing the financial reporting process. Yes - for most private companies - especially those that are "owner-managed" - management (i.e. the executive directors) will be "TCWG" according to this definition. There's no reason why owner-managers should not determined their own rewards :-) So it is only when thinking about listed/public entities that you need TCWG to be separate from management - hence the UK Corporate Governance Code's requirements for oversight by non-executive directors.