Hubbell Policies

Prohibited Actions: Anti-fraud, Anti-manipulation, and Disruptive Trading Practices All Hubbell employees shall comply fully with the provisions of federal and state laws, rules and regulations of governmental agencies and the internal policies of Hubbell. Each employee must not, among other prohibited acts, in connection with any swap:

• Manipulate or attempt to manipulate prices;

• Directly or indirectly engage in any fraudulent or deceptive act;

• Directly or indirectly make any untrue statement of a material fact;

• Omit to state a material fact necessary to make the statements made, in the light of the circumstances under which they were made, not misleading; • Engage in any disruptive trading practice, including, without limitation, violating bids or offers, demonstrating an intentional or reckless disregard for the execution of transactions during the closing period, or engaging in any conduct that is commonly known as “spoofing”; • Misuse or disclose confidential or material, non-public information in relation to swaps trading activity in a manner not permitted by a confidentiality or nondisclosure agreement, if any;

• Engage in pre-arranged or noncompetitive trading on a listed derivatives market;

• Make false records; and/or

• Cooperate or collude with any party to violate any of the above prohibitions or to engage in any other violation of law. Major Swap Participant Assessment Hubbell intends to maintain its status as a non-major swap participant (“MSP”). MSP registration is required where daily current uncollateralized exposure exceeds $3 billion in rate swaps or $1 billion in credit, equity, or commodity swaps or where current uncollateralized outward exposure plus potential outward exposure exceeds $6 billion in rate swaps or $2 billion in credit, equity, or commodity swaps. At any time the notional amount of our swaps exceeds $3 billion with respect to rate swaps or $1 billion with respect to credit, equity, or commodity swaps, we are required to conduct quarterly calculations to ensure that we do not qualify as an MSP. ADMINISTRATION Roles and Responsibilities. Key Treasury and accounting functions must be adequately segregated to detect possible fraud, mistakes, misappropriation of funds, unauthorized deals and concealment of trades.

Treasury Activity Development of Exposure

Role

Accounting Activity Non-SAP G/L Data

Role

Authorized Treasury Staff

Authorized Accounting Staff

Approval of Transactions CFO or Treasurer

n/a

n/a

Execution of Trades

Authorized Treasury Staff

Inbound Confirmation Bank Reconciliation

Authorized Accounting Staff Authorized Accounting Staff

Outbound confirmations Treasurer or Director of Treasury

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