No, I don't believe these things are mutually exclusive. Every structure has a person within the organization who is trusted, to whom someone can go who has a concern about an ethical issue, a conflict of interest, or something like that, because ADR, alternative dispute resolution, and things like that are preferable, depending on what the issue is--an independent voice, as long as the person has some moral character and fibre and is prepared to discharge the job, and is allowed to do it. But this isn't a case of either/or. You also have to have something whereby someone stands independently. My career path is not dependent upon the commissioner's good grace or anything else; I'm here for a term, and then they replace me with someone else. It's always refreshed.
I think what you're looking at is an array of things—the toolbox that they talk about. You have that as a step. You don't want to formalize everything, but you have to have a formal structure where you can come in and say, “I'm looking at this. Here are my recommendations. And they're not going to be in-house; I'm going public with this.” In some of my reports—in the appropriate case—I go public, because there has to be a bit of a shaming and naming process to it.