There is a major reason why Equal Employment Opportunity should never be placed in the Human Resources Department:
An effective EEO office will have to investigate the Human Resources Department.
It's a simple fact. HR handles the selection process and also puts its prints on terminations and many personnel actions in-between. Those areas are prime generators of discrimination complaints. The CEO should have an independent voice that can provide objective investigations. Human Resources cannot credibly investigate itself.
Some may say, "Well, both EEO and HR work for the same employer so how can any of them be objective?" That's a good question but it assumes that economic ties are stronger than professionalism or commitment. I've worked as an internal EEO officer and frequently sided with charging parties in discrimination cases. It made no sense to rubber-stamp management decisions that were discriminatory. Doing so would destroy the credibility of the internal complaint process and open the organization to even worse problems.
If an organization cannot afford to have a separate internal EEO officer, then it should contract out that responsibility. Leaving the role to HR is a huge mistake.
It is also a common one.