Hubbell Policies

E. E&O Worksheet data quality checks i.

All quantities related to usage or on-hand inventory are positive in the calculation worksheet (or there is documentation of why negatives are reasonable); ii. All inventory dollar amounts contained in the worksheet are positive (or there is documentation about why negatives are reasonable); and iii. Part number’s / SKU ’s are valid per SAP . Quarterly - Each business is responsible for testing the data in the PBI model. The testing will include validating SAP to PBI and validating PBI to SAP, by agreeing the quantity on hand, cost, and three year usage of the SKU selected. a. For 16 samples from SAP to PBI - The company codes will use data from SAP t-codes MC.9 or MB5L sorted from high to low based on inventory valuation. They will then pick every 25th part until 16 sample parts are selected. b. For the 16 samples from PBI to SAP - The company codes will use the PBI data sorted high to low based on total E&O reserve. They will pick the top 16 parts to test. If there is any duplication of part numbers from above, no expansion of scope is necessary. 1. Reconciliation of inventory listing total used in the E&O analysis to the GL (quarterly). 2. Perform a clerical accuracy test of the calculation/spreadsheet (i.e. sampling a selection of rows across to ensure accuracy of the formulas and footing totals) (semiannually). 3. For businesses not using PBI, on an annual basis, a review of the GL or application being used must be conducted to confirm the BU’s understanding of the latest process with a documented (management signed) narrative which addresses, (a) process steps used in gather information, (b) system codes and definitions used to determine inventory/quantity designation as excess and/or obsolete, (c) any timing differences in the age of the data (for example, is there a lag in this reporting versus the GL).

(3) Electronic Audit Evidence minimum review requirements

ADMINISTRATION Roles and Responsibilities

The business unit Controller is responsible for ensuring the reserve on the GL agrees to the amount per the last E&O analysis and that the E&O analysis is performed quarterly and meets all the requirements defined in this Policy.

Monitoring, Evaluation and Review An analysis and calculation of E&O inventory must be performed quarterly, and the E&O reserve adjusted in line with the analysis. Exceptions In order to obtain an exception to this Policy a written request must be submitted to the VP, Corporate Controller that contains a compelling business reason why the Policy cannot be adhered to.

ACCOUNTING AND DISCLOSURE Business Use Not applicable.

Personal Use Not applicable.

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