John Davis was quoted regarding the announcement of Cognizant Technology Solutions Corporation's $25 million settlement with the U.S. Securities and Enforcement Commission (SEC), along with the issuance of a declination letter by the Department of Justice (DOJ), over allegations of Foreign Corrupt Practices Act (FCPA) violations related to payments made to secure permit approval for the construction of a facility in India. "The company clearly benefitted from its remedial actions under the DOJ's FCPA Corporate Enforcement Policy, as it obtained a declination from any DOJ action against the company in spite of the aggravating circumstances created by the involvement of senior corporate executives in the alleged bribery scheme," Davis said, noting that self-disclosure seems to have played a positive role in the outcome of the matter. "The public documents cite the quick disclosure of the potential payments to the agencies at the direction of the company's board within two weeks of the board being notified of the issue and the existence of a compliance program that was in effect at the time of the payments as key mitigating factors," he said.