Hubbell Policies

Spare parts - Over $5,000, Capitalize and depreciate. OTHER Laptops and personal computers - Expenses when incurred. ADMINISTRATION Roles and Responsibilities. Business unit controllers have responsibility in overseeing compliance with this policy.

Monitoring, Evaluation and Review.

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

3. PPE 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 a written exception to this policy, a written request must be submitted to the Corporate Controller that contains a compelling business reason for the exception. Examples would include bulk purchases of similar purpose PPE whose individual unit costs are less than or equal to the capitalization threshold. Exceptions granted by the Corporate Controller must be retained by the business unit as supporting documentation. ACCOUNTING AND DISCLOSURE None REPORTING None DEFINITIONS Property, Plant and Equipment shall mean includes all expenditures for real and personal property directly related to the acquisition or construction of, and the preparations for its intended use. Unit of Property (UoP) shall mean functionally interdependent machinery or equipment performing industrial process, further broken up to smaller units that perform a discrete major function. Betterment shall mean A) Corrects material defects, B) A material addition (physical enlargement, expansion, extension or addition of a major component) and/or C) Reasonably expected to materially increase strength, productivity, efficiency, quality or output of the UoP. Adaptation shall mean amounts paid for adapting a UoP to a new or different use inconsistent with the intended use of UoP when originally placed in service Restoration shall mean A) Returning UoP to it ordinary efficient operation condition if the property has deteriorated to a state of disrepair and is no longer functional for its intended use, B) Replacement of a part or combination of parts that comprises a major component (or significant portion of a major component for building property) or substantial structural part, C) Rebuilding of a UoP to a like new condition after the end of its class life or D) Restoration of damage to a UoP for which the taxpayer is required to adjust basis as a result of a casualty.

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