Cognizant Technology Solutions (“Cognizant”) is global information technology services provider headquartered in New Jersey. Sridhar Thiruvengadam, an Indian national, was the former Chief Operating Officer.
Cognizant maintains common stock registered under Section 12(b) of the Exchange Act that is publicly traded on NASDAQ. Cognizant India is a subsidiary based in India.
According to the SEC, Thiruvengadam was aware of and helped conceal bribe payments in India which were paid to obtain planning permits for construction projects by Cognizant. The SEC alleges that Thiruvengadam was aware of bribery demands by Indian government officials and was aware of, but failed to prevent, a plan devised by Cognizant executives and officers to pay bribes through contracting firms and concealing the payments through fake contract change orders.
According to the SEC, despite Thiruvengadam’s knowledge, he signed falsified management subcertifications for Cognizant’s audits from 2014 through 2016. In so doing, Thiruvengadam falsely certified that he was unaware of any fraud implicating senior management, and the company’s CEO and CFO relied on this misrepresentation in signing and sending management representation letters to the company’s outside auditor. The auditor relied on this misinformation in issuing an opinion as to the company’s financial statements.