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Not just CEO. I would say he might have known even less of procedures in detail than middle management. You wouldn't pardon all Nazis just because Hitler was on top, would you? If what you do willingly is non-ethical even if you don't call the shots, you are just as bad.
Well yeah there is a gradient of culpability but it roughly follows the gradient of power and compensation, which is an exponential curve with the lion's share of the area under the curve contained within the very very top.
If you want to get technical about it, if the average CEO earns 300 times the average (not the lowest) pay of employees at the company than sure, the average employee has culpability but it is 1/300th or less of the culpability of the people truly at the top and that is likely a conservative estimate of gulf between those two values.
Obviously one doesn't somehow nullify the other but the structure of culpability here has to be taken into account in order to make an honest analysis.