This is exactly it. In a large organization, everyone can mentally offload any responsibility to someone else.
The rank and file can say "It's not my decision, the execs told me to do this".
The executives can say, "It's the board pushing me to do xyz and if I don't do it then someone else will, so I might as well just keep my job".
And the board can say, "Well, we just told the execs to maximize shareholder value, we didn't tell them to do anything unethical."
So you end up with a situation where no one feels like they bear any responsibility for the actions of an enterprise and you have a group of individuals who, as individuals, are moral but are contributing to an organization that is acting immorally in the aggregate.