Hubbell Policies

CRITICAL SPREADSHEETS POLICY

English

Owner : Vice President, General Counsel

Last Review: 2015.06.25

FIN – 16

Department: Corporate Legal

POLICY

This policy requires a business to maintain an inventory listing of critical spreadsheets. The following procedure also describes the annual review process to be conducted by the Group Controller and the access and security that is required for critical spread sheets.

SCOPE

This policy applies to all business units and all spreadsheets that meet the criteria established in the following procedure.

PURPOSE

The purpose of this policy and related procedure is to define the identification of critical spreadsheets and the required review, access and security procedures.

PROCEDURE

Critical Spreadsheet Identification Spreadsheets that compute or store key financial information impacting financial reporting need to be identified as critical and included on an inventory listing that is retained centrally. The inventory listing will be maintained on the “Inventory of Critical Spreadsheets” template. On an annu al basis, the Group Controller will review spreadsheets utilized in the financial reporting processes within the scope of his/her business and update the Inventory of Critical Spreadsheets template accordingly.

The following types of spreadsheets must be classified as critical.

1. Any spreadsheet, offline database, or file used to perform a calculation that supports a balance sheet asset or liability account with an average annual balance of $1 million or greater or income statement account with an annual balance of greater than $250,000.

2. Any other spreadsheet identified as critical by the Group Controller or the Corporate Controllers office.

a. Examples include spreadsheets with complex formulas and calculations or multiple sources of inputs in order to calculate information used to support journal entries, forecasts, or other forms of financial reporting. Examples of complex formulas or calculations include, but are not limited to, macros, links to other spreadsheets, large number of interrelated and linked tabs, etc.

3. Spreadsheets used on a recurring basis that directly support external financial statement disclosures (for example spreadsheets calculating data used in 10-K, 10-Q, or proxy filings with the SEC).

Access and Security All critical spreadsheets must be password protected or stored in a folder with restricted access. Critical spreadsheets should be stored on a shared drive and backed up on regular basis and must never reside on a local C: drive.

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