Hubbell Policies

The owner of a critical spreadsheet should identify another member of his/her department that understands the purpose of the spreadsheet and how it functions. This individual must also have access to the restricted folder or password, whichever applies. It is the responsibility of the manager of the owner of the critical spreadsheet to understand what the spreadsheet is used for and its location and password.

Verification and testing The following tests and verifications must to be performed for all critical spreadsheets.

1. All critical spreadsheets must be included in the inventory listing (using the Inventory of Critical Spreadsheet Template).

2. All spreadsheets identified as critical must be independently reviewed by the manager of the owner of the critical spreadsheet to ensure formulas and the source of data is accurate before the spreadsheet is utilized.

3. All critical spreadsheets must be independently reviewed annually for mathematical accuracy (i.e., that the spreadsheet is calculating as intended) and ensure formulas and the source of data is accurate.

4. Sign off on the results of the review of each critical spreadsheet must be documented in BlackLine in the task module.

ADMINISTRATION

Roles and Responsibilities. The Group Controller is responsible for ensuring all critical spreadsheets affecting financial reporting are identified and listed in the Critical Spreadsheet Inventory Template.

The critical spreadsheet user is responsible for controlling the access and security of the critical spreadsheets (storage, version controls, document encryptions, etc.).

Monitoring, Evaluation and Review. The Group Controller is responsible for ensuring that tests are performed as required per the policy for critical spreadsheets.

Exceptions. None

ACCOUNTING AND DISCLOSURE

None

REPORTING

None

DEFINITIONS

Independently tested shall mean tested by an individual not involved in creating the spreadsheet.

Business Unit Controller shall mean for purposes of this procedure, the Assistant Corporate Controller and Tax group will have the same responsibilities as a Group Controller with regard to critical spreadsheets relating to the corporate and tax functions, respectively.

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