Jay MartinThis Thursday 19th May, the Greater Houston Business and Ethics Roundtable (GHBER) will hold its first Ethics and Compliance Awards Dinner in honor of the 20-year anniversary of the organization’s founding. We will award the Bette Stead Leadership Award (Stead is the founder of GHBER) to Jay Martin, Vice President (VP), Chief Compliance Officer (CCO) and Senior Deputy General Counsel (GC) at BakerHughes Inc. (BHI). Martin is certainly one of the top compliance professionals, not only in Houston but across the country and globe as well. This month, I was privileged to publish an interview with Martin in the SCCE Magazine. Today, I wanted to write about what Martin means to our profession from a more personal perspective.

Martin came on board with BHI in 2004, during its Foreign Corrupt Practices Act (FCPA) investigation culminating with its fine of $44 million. I distinctly remember the fine amount, assessed in 2007, because it knocked my then employer, the Norwegian company Abel, off the top slot for all-time FCPA fines. (Abel’s fine was $27MM.) Since Martin joined BHI, the company has had no reportable FCPA violations. In the city of Houston, the single city on the globe with the largest number of FCPA enforcement actions, this is quite an accomplishment.

Martin has been around the ethics and compliance world for quite some time. Yet throughout this time, he has been unremitting in not only his commitment to ethics and compliance at BHI but also the profession. I first met Martin in 2007 at a roundtable put on by Baker McKenzie. Paul McNulty led the Roundtable after he left the Department of Justice (DOJ) during the interim period when he could not work on federal cases or negotiate with his former DOJ compadres. So he was sent across the country on business development Roundtables. Martin was there and talked frankly about his experiences with creating a compliance program and culture of compliance at BHI.

Martin was absolutely clear that the reason BHI was able to turn things around was the commitment from top leadership of the company, specifically starting with Chairman and Chief Executive Officer (CEO) Martin Craighead. Martin said that without Craighead’s unremitting support, he never would have been able to create a best practices compliance program. The power of this message drove home to me, that it really does all start at the top and unless you have such commitment, you will have a difficult time creating and maintaining a top-notch compliance program.

This initial meeting with Martin was the first of many professional encounters I have had with him over the years. I have heard him speak at such prestigious and well known events as the Compliance Week annual conference, the annual SCCE Compliance and Ethics Institute and other similarly nationally focused events. I have also heard him speak at local compliance related events in Houston and even at the Compliance Roundtable founded by Mike Snyder and myself.

But more than just his public speaking events and the scholarly and practical articles that Martin produces, he is always available to answer the simplest or most straightforward question about compliance. He has made clear that you can email or ring him up and he will respond. His knowledge of almost any issue on compliance is about as wide and as deep as anyone around. In short, he is a great resource.

Yet there is one other thing that has struck me about why Martin is such a significant contributor to the ethics and compliance profession. He is now on his third generation of compliance practitioners working under him or for him at BHI. The first generation of compliance professionals who worked under him are now high profile CCOs themselves. The first generation of compliance professionals who worked and trained under Martin include Rod Hardie, Dan Chapman, Doug Walters and John Sadr. All well known and well respected, in both Houston and across the globe, for their work in compliance.

Most of my corporate experience around seeking to move up to a more challenging position was by changing employers, and consisted of something along the lines of “don’t let the door hit you on the way out”. Yet Martin not only encourages folks to seek greater opportunities but also fully supports them in moving up to the CCO chair. I once asked him why he had this philosophy and he told me that he hires the top talent, works them quite diligently and when they are ready to move up he will support them. He also made clear that compliance practitioners will work very hard at BHI but with the training Martin provides, coupled with the robustness of the BHI compliance program, he feels his team should have the chance to progress in the profession. All I can say is how refreshing.

As I noted above, my home city is both blessed and cursed as begin at the epicenter of FCPA enforcement, due to the first wave of FCPA enforcement actions centering on the energy industry. Yet this early wave of enforcement led to Houston based corporations having not only more robust compliance programs earlier than companies in other industries but now having more mature programs in terms of where they may be on the best practices continuum.

From what it went through when Martin came on board, BHI is certainly one of those companies. Yet throughout all of this Martin has been an industry leader in the practice of compliance. He is also a leader in the profession of compliance. He is and has been there to help others not only learn the nuts and bolts of compliance but what it means to do compliance. His (designed or not) training program for compliance professionals at BHI has developed and provided many other companies with top notch CCOs and compliance professionals.

I hope you join me in congratulating Jay Martin. For more information on the GHBER first annual Ethics and Compliance Awards Dinner, click here.


This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2016