United States securities and exchange commission logo
September 12, 2023
Paul Schmidt
Chief Financial Officer
Gold Fields Limited
150 Helen Road
Sandown, Sandton, 2196
South Africa
Re: Gold Fields Limited
Form 20-F for the
Fiscal Year Ended December 31, 2022
Filed March 30,
2023
File No. 001-31318
Dear Paul Schmidt:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022 Filed March 30,
2023
Summary Disclosure of Mining Operations Pursuant to Item 1303 of
Regulation S-K under the
Securities Act, page 30
1. We note your summary
disclosure includes operating properties, however does not appear
to include all
properties in which you have a direct or indirect economic interest, as
required by Item
1303(a)(1) of Regulation S-K. For example we note your disclosure on
page 84 of your
Integrated Annual Report regarding strategic investments that have not
been included in your
summary table. Please revise your summary disclosure to include
all properties in which
you have a direct or indirect economic interest, as required by Item
1303(a)(1) of
Regulation, including the disclosure required under Item 1303(b) of
Regulation S-K.
Paul Schmidt
FirstName
Gold FieldsLastNamePaul Schmidt
Limited
Comapany 12,
September NameGold
2023 Fields Limited
September
Page 2 12, 2023 Page 2
FirstName LastName
Exhibits
2. We are unable to locate your mining and processing schedule in the
Cerro Corona Copper
and Gold Mine technical report summary dated December 31, 2022, filed
as Exhibit 96.8.
For example, page 95 includes a reference to the Cerro Corona Copper
and Gold Mine
mining and processing schedule in Section 12.2, however the schedule
appears to be
missing. Additionally in Table 19.1.1 on page 96 of the Cerro Corona
technical report
summary, we are unable to reconcile the quantities sold, with the LOM
processed, when
applying the recovery percentage. Please advise.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact John Coleman at 202-551-3610 or Craig Arakawa at
202-551-3650 if
you have questions regarding comments.
Sincerely,
Division of
Corporation Finance
Office of Energy &
Transportation