Hubbell Policies

FINANCIAL STATEMENT TRANSLATION POLICY

English

Owner : Vice President, Controller

Last Review: 2014.08.10

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Department: Finance

POLICY This policy requires all entities to translate transactions denominated in a currency other than the reporting entity’s Functional Currency using the Corporate Published Average Monthly Exchange Rate. SCOPE This policy applies to all Hubbell business units. PURPOSE The objective is to ensure compliance with United States Generally Accepted Accounting Principles (GAAP) and ensure accounting and reporting for foreign currency exchange is applied consistency across all Hubbell business units. PROCEDURE Monthly financial statements submitted into Hyperion Financial Management ("HFM") must be translated using the Corporate published foreign currency exchange ("FX") rates to the fifth decimal point. Balance Sheet accounts, excluding Investment in Affiliates (HFM1640), Capital Stock (HFM2610), Capital Surplus (HFM 2620), Retained Earnings (HFM 2630), Dividends (HFM 2640), Unamortized Pension and OPEB (HFM 2633), must be translated using the month-end exchange rate while Income Statement accounts must be translated using the average exchange rate for the current month. Excluded Balance Sheet accounts are to be reported in USD at historical exchange rates in the following HFM USD override accounts:

• USD1640 Investment in Affiliates

• USD 2610 Capital Stock

• USD 2620 Capital Surplus

• USD 2630 Retained Earnings

• USD 2640 Dividends Declared

• USD 2633 Minimum Pension Charge

Corporate Finance will publish via e-mail the FX rates to be used for U.S. GAAP financial reporting through HFM. These FX rates are generally published within the last two business days of each calendar month. ADMINISTRATION Roles and Responsibilities. The Business Unit Controller is responsible to ensure compliance with this procedure.

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