Hubbell Policies

• All independent verifications of notional amounts, mark-to-market values and counterparty credit ratings for outstanding swap transactions. • All e-mails, electronic communications, and other written communications received from or provided to counterparties (including potential counterparties). • The counterparty’s legal entity identifier "LEI" or CFTC interim compliant identifier "CICI", as applicable.

• Any records relating to the reporting of the swap to a Swap Data Repository ("SDR").

• The internal product identifier or product description used by any SDR to which the swap is reported.

• The unique swap identifier assigned to the swap by the SDR.

The records relating to any swap shall be kept for the life of the swap and for at least five years following the final termination of the swap. The records may be maintained in paper or electronic form; however, all records must be retrievable within 5 business days. The records of Hubbell shall reflect swaps activities accurately, completely and fairly. Hubbell personnel are prohibited from making false or misleading entries in Hubbell’s books and records and from assisting others, including counterparties, in creating false or misleading books, records or entries. Reporting Obligations for the End-User Exception To the extent Hubbell intends to rely on the end-user exception to the requirement under Dodd-Frank to clear swaps, Treasury shall ensure that all applicable reporting requirements are met, including, as appropriate, submission of an annual filing to an SDR containing the information identified below:

• That Hubbell is not a financial entity;

• That Hubbell is using swaps to hedge or mitigate commercial risk;

• How Hubbell meets its financial obligations with respect to its swaps; and

• Hubbell is an issuer of securities that have received board approval to elect not to clear.

In addition, when Hubbell relies on the end-user exception, it (or its counterparty) will provide the following information for reporting to an SDR:

• Notice the parties are electing to use the end-user exception; and

• Hubbell’s identity as the electing counterparty to the swap.

Institutional Suitability Hubbell personnel are required to exercise independent judgment in evaluating the recommendations of any swap dealer with regard to the relevant swap or trading strategy involving the swaps. Additionally, any person responsible for evaluating the recommendations of any swap dealer or making decisions on behalf of Hubbell with respect to swaps must be capable of fully understanding the potential risks and rewards associated with the recommended swap or trading strategy involving a swap. The persons to whom authority has been given under this Policy have been determined to satisfy such requirements.

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