Absolutely - though the flip side of this is if something is everybody responsibility - it's nobodies.

There are two things to successful organisations structure and people, you are focusing only on the structure.

What you need for somebody responsible for health and safety, ethics, security, or compliance is a person who has courage and is willing to take calculated risks.

However these roles do have a tendency to attract the risk adverse, or make them risk adverse if you punish risks that go wrong too harshly.

And a key critical success factor is leadership from the top - companies have personalities and leaders in the organisation are very important in shaping that.