Given the author admits: > Note that those outside the company, such as investors or regulators, seem like they should effectively count as a level under some

Given the author admits: > Note that those outside the company, such as investors or regulators, seem like they should effectively count as a level under some circumstances, but not under others. I think there's obviously some room to fudge with what the exact boundaries of the "organization" are. So yeah, maybe a sufficiently-empowered department head functions more like a CEO/boss.