An apology translated into procedure may never reach the person who needed it.

When an apology becomes a process, it stops being an apology. A form is completed, a statement is issued, a box is ticked, and the person who was actually harmed receives something that acknowledges nothing in particular and comes from no one. The requirement is satisfied and the need is not.

If you owe someone an apology, deliver it yourself, name the specific thing, and do not attach an explanation to it. Procedures have their place for the record. They cannot do the part that only a person speaking directly to another person can do.