Hubbell Policies

RESTRUCTURING AND RELATED COSTS POLICY

English

Owner : Vice President, Controller

Last Review: 2016.05.25

FIN – 43

Department: Finance

POLICY This policy establishes the procedure for identifying and recording restructuring and related costs.

SCOPE

The policy applies to all business units.

PURPOSE

To clarify the procedure that is required for restructuring and related costs.

PROCEDURE

Restructuring costs are narrowly defined by U.S. GAAP and support our cost reduction efforts involving the consolidation of manufacturing and distribution facilities, workforce reductions, and the sale or exit of business units we determine to be non-strategic. When we refer to “ Restructuring Costs ” , we are referring to those costs that meet this narrow definition in U.S. GAAP. “Restructuring - related costs” include mainly consulting and other costs that do NOT meet the narrow definition of Restructuring Costs and are primarily the costs of strategic investments associated with our business transformation initiatives, including the consolidation of back-office functions and streamlining our processes. Our external reporting (including SEC filings, Earnings Press release and Call Slides) and in this procedure we will frequently refer to these costs on a combined basis as "Restructuring and Related Costs", which is a non-GAAP measure. Restructuring Costs are subject to specific U.S. GAAP and SEC reporting requirements. Restructuring and Related Costs are separately reported in Hubbell’s SEC filings and earnings press release. Therefore, Hubbell has established specific procedures related to the accounting and reporting for these costs.

1. Approval

All restructuring and related activities must be approved by completing a Special Charges AFE template. The Special Charges AFE template requires the following approvals:

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