Hubbell Policies

Settlement & Input of Trades Management Reporting

Authorized Treasury Staff

Posting & Recon to G/L

Authorized Accounting Staff

Authorized Treasury Staff

Posting to G/L

Authorized Accounting Staff

Derivatives Policy Compliance Valuation/Mark-to Market

Treasurer or Director of Treasury

n/a

n/a

Authorized Treasury Staff

Monthly mark-to-market entry

Authorized Accounting Staff

Monitoring, Evaluation and Review. Internal audit will formally test compliance and Policy effectiveness on an annual basis. During daily Treasury operations, Treasury staff will spot check and confirm Policy compliance. Amendments, Policy updates and revisions will also be tested for compliance. Exceptions. Exceptions to the Policy will be handled on a case by case basis and will be well documented before they are executed. ACCOUNTING AND DISCLOSURE None REPORTING See Roles and Responsibilities Section. DEFINITIONS Derivative shall mean a derivative is a financial contract which derives its value from the performance of another entity such as an asset, index, or interest rate, called the "underlying". Hedge shall mean a hedge is an investment position intended to offset potential losses/gains that may be incurred by a companion investment. Dodd-Frank shall mean the Dodd-Frank Act implements changes that, among other things, affect the oversight and supervision of financial institutions, provide for a new resolution procedure for large financial companies, create a new agency responsible for implementing and enforcing compliance with consumer financial laws, introduce more stringent regulatory capital requirements, effect significant changes in the regulation of over the counter derivatives, reform the regulation of credit rating agencies, implement changes to corporate governance and executive compensation practices, incorporate the Volcker Rule, require registration of advisers to certain private funds, and effect significant changes in the securitization market. EMIR shall mean in order to address the roots of the financial crisis, the G20 countries committed to address risks related to the derivative markets. In order to make that commitment effective, the European Parliament and the Council have adopted a regulation that requires OTC derivative contracts to be cleared, derivative contracts to be reported and sets a framework to enhance the safety of central clearing counterparties (CCP) and for Trade Repositories (TR). This regulation was adopted on 4 July 2012 and entered into force on 16 August 2012. It is directly applicable in all the European member states.

Swap - The Commodity Futures Trading Commission, "the CFTC" defines Swaps as the following:

• Foreign Currency Options

• Non-Deliverable Forwards in Foreign Exchange

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