TRACE International |

TERADATA CORPORATION

Industry

Technology / Software / Electronics

Corporate Headquarters

Dayton, Ohio, United States

Nationality of Foreign Officials: Turkey

Summary of Allegations:

On 4 August 2017, Teradata Corporation disclosed in an SEC filing that through internal processes it discovered questionable expenditures for travel, gifts and other expenses at a subsidiary doing business in Turkey.

Approximate Alleged Payments to Foreign Officials: Unspecified gift and hospitality related expenses.

Business Advantage Allegedly Obtained: Unspecified.

Enforcement Results

Agencies: Internal Investigation

Results:

Year Resolved: 2018

Compliance Monitor:

Ongoing: No

Details:

Q2 2017 - Teradata initiated an internal investigation into its subsidiary's questionable gift and hospitality related expenses in Turkey to determine whether they violated the FCPA or other anti-corruption laws. Teradata retained outside counsel and forensic accountants to assist in the investigation, and reported all findings to the SEC and DOJ in an effort to cooperate in their respective investigations.

Agencies: United States: Department of Justice, United States: Securities and Exchange Commission

Results: Declination

Year Resolved: 2018

Compliance Monitor:

Ongoing: No

Details:

February 2017 - Teradata voluntarily alerted the SEC and DOJ to its discovery and internal investigation of a subsidiary's questionable gift and hospitality related expenses in Turkey.

16 January 2018 - The SEC closed its investigation without enforcement action.

20 February 2018 - The DOJ closed its investigation without enforcement action.

ENTITIES / INDIVIDUALS INVOLVED

Teradata Corporation

Details Of How Conduct Was Discovered

Discovery Method: Internal Investigation

Details:

Country: