Hubbell Policies

the receiving entity from where it had left off (i.e. carryover). The jurisdiction code for the asset should be updated to reflect the new jurisdiction, if applicable, for property tax purposes. For tax purposes a transfer may be required to be conducted at fair market value (which may be the case when a transfer occurs between two different tax jurisdictions). In those cases the U.S. GAAP books of the receiving and selling entities must still reflect the transfer at NBV and any gain or loss should be recognized as the difference between the fair market value and NBV at the date of the transfer. The gain or loss must offset; if the selling entity has a gain, then the receiving entity will have an equal and offsetting loss. The selling and receiving entities must each record any gain or loss in HFM 3491 so that it is properly eliminated in consolidation. From a materiality level perspective, only domestic transfers with a cost basis of greater than $500K and all international cross border transfers should be reviewed by the Corporate tax team. The controller of the selling entity is responsible for ensuring any gain or loss has been properly recorded by both the selling and receiving entities in HFM 3491 and that the net impact is zero. For statutory reporting purposes, follow local reporting requirements, which may be different from U.S. GAAP. Held for Disposition: Land and/or building that have not been physically disposed but are instead held for disposition or sale should be reclassed for book purposes from PPE to a Property Held for Investment ("PHI") general ledger account at the lower of the asset's net book value or fair value, reduced for incremental costs to complete the disposal. Prior Corporate approval is required for such reclasses. For book purposes, depreciation will cease once the asset is transferred to PHI. For tax purposes, PHI should not be written down as it should remain in the fixed asset subledger and continue being depreciated until that time the property is ultimately sold. Once the asset is physically disposed, the guidance above should be followed for both book and tax purposes. ADMINISTRATION Roles and Responsibilities. Business unit controllers have responsibility in overseeing compliance with this policy.

Monitoring, Evaluation and Review.

1. Internal Audit reviews are performed periodically at the discretion of the local, group, or Corporate management. 2. SOX key controls relevant to PPE are reviewed and tested bi-annually.

3. PPE subledger and general ledger accounts are reviewed and reconciled at each period-end close.

4. Business process / financial performance reviews conducted at each period-end close.

5. PPE physical inventory on three year cycle.

Exceptions. In order to obtain an exception to this procedure a written request must be submitted to the Vice President, Controller that contains a compelling business reason. ACCOUNTING AND DISCLOSURE None

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