Alto Palermo S.A. (APSA)

D. Changes in Internal Control Over Financial Reporting
During the period covered by this Annual Report on Form 20 F, the company has implemented a new
ERP software. The Company’s internal control over financial reporting has been adapted accordingly, for the
change in our accounting system. After carrying out an evaluation under the supervision and with the
participation of our management, of the effectiveness of the design and operation of our disclosure controls and
procedures, the Company concludes that our disclosure controls and procedures were effective.
ITEM 16.
A. Audit Committee Financial Expert
In our annual ordinary shareholders’ meeting held on October 31, 2003, the audit committee plan was
unanimously approved. Pursuant to this plan, the Board of Directors shall appoint the members of the audit
committee. The Board of Directors established that the Audit Committee shall be a Committee of the Board of
Directors. The Audit Committee will focus on assisting the Board in exercising its duty of care, the
enforcement of accounting policies, disclosure requirements, the management of our business risk, the
management of our internal control systems, the ethical conduct of the company’s business, maintenance of the
integrity of our financial statements, compliance with legal provisions, the independence and capability of our
independent auditors and the performance of our internal audit function and of our external auditors.
On November 7, 2007, our board of directors officially appointed Leonardo Fernández, Abraham
Perelman and Enrique Antonini, all of them whom are independent members, as members of the audit
committee in accordance with Rule 10(A)-3(b)(1) of the General rules and regulations promulgated under the
Securities Exchange Act of 1934. We have a fully independent audit committee as per the standard provided in
Rule 10(A)-3(b)(1). Although all of them have large corporate experience, as of the date of this annual report,
the Board of Directors have not named a financial expert in accordance with the relevant SEC rules.Argentine
law does not require companies to identify or designate a financial expert. As such, the Board of Directors have
not designated a financial expert on the audit committee. Although it is noted that all members of the audit
committee have had significant corporate experience.
B. Code of Ethics
We have adopted a code of ethics that applies to our directors, officers and employees. On date July 25
2005, our Code of Ethics was amended by our Board of Directors. The reformed Code was informed by means
of a 6K Form filing on August 1, 2005. Our code of ethics is available on our web site at www.apsacc.com.
An Ethics Committee comprised by three members of the board of directors how will be responsible for
the solution of issues related to the Code of Ethics for Directors and officers and shall determine the appropriate
disciplinary action for any violation of such Code of Ethics.
If we make any substantive amendment to the code of ethics, we will disclose the nature of such
amendment on our website, www.apsacc.com or in our next Form 20-F. If we grant any waivers, including any
implicit waiver, from a provision of the code of ethics, we will disclose the nature of such waiver in a Form 6-
K or in our next Form 20-F.
C. Principal Accountant Fees and Services
Audit Fees
During fiscal years ended June 30, 2007 and 2006, we were billed for a total amount of Ps. 0.9 million
and Ps. 0.5 million, respectively, for professional services rendered by our principal accountants for the audit of
our annual financial statements and other services normally provided in connection with regulatory filings or
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