United States securities and exchange commission logo
March 8, 2024
Boipelo Lekubo
Financial Director
HARMONY GOLD MINING CO LTD
Randfontein Office Park
CNR Ward Avenue and Main Reef Road
Randfontein, South Africa 1759
Re: HARMONY GOLD MINING
CO LTD
Form 20-F For the
Fiscal Year Ended June 30, 2023
Response dated
February 20, 2024
File No. 001-31545
Dear Boipelo Lekubo:
We have reviewed your February 20, 2024 response to our comment
letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our January 19,
2024 letter.
Form 20-F For the Fiscal Year Ended June 30, 2023
96.12 Technical Report Summary of the Mineral Resources and Mineral
Reserves for Tshepong
North, Free State Province, South Africa, page 189
1. We note your response
to comment 2. The provisions in S-K 1300 preclude the inclusion
of inferred resources
in an economic analysis that supports a property's economic
viability. For example,
pursuant to Item 1302(e)(6) of Regulation S-K, a qualified person
must exclude inferred
mineral resources from a pre-feasibility study's demonstration of
economic viability in
support of a disclosure of a mineral reserve. Please obtain and file a
revised Tshepong North
technical report summary from your qualified person to comply
with this requirement.
Please review your other technical report summaries and make
arrangements with your
respective qualified persons to revise as necessary to comply with
this requirement.
Boipelo Lekubo
HARMONY GOLD MINING CO LTD
March 8, 2024
Page 2
Exhibit 99.1
Notes to the Group Financial Statements
15 Property, Plant and Equipment
Depreciation, page F-33
2. Please revise your future filings to provide a critical accounting
policy for depreciation
that addresses your method of depreciating mining-related assets.
Please address the
following items:
Define each of proven and probable reserves, measured and
indicated resources and
inferred resources;
Describe the circumstances under which each type of resource
is included in the
calculation of depreciation, describe management s assumptions
concerning these
resources (i.e., circumstances under which the resources may be
economically mined,
additional timing and work to convert the resources to reserves,
gold pricing
concerns, etc.), and describe management s track record
regarding the conversion of
resources to reserves;
Disclose the nature and amount of resources that are included
in the depreciation
calculation for each year for which an income statement is
presented;
Disclose the amounts and percentages of variances between the
amount of
depreciation calculated including these resources and the amount
of depreciation
calculated without these resources;
Describe how you risk weighted the resources included in the
depreciation
calculation; or if you do not risk weight those quantities,
explain why;
Disclose whether additional development costs are also included
in the calculation of
depreciation and how those costs are determined. If so, disclose
the amount of
additional development costs that were included in the
depreciation calculation for
each year for which an income statement is presented;
Provide all of the requested disclosures on an overall basis and
on a mine-by-mine
basis as necessary.Lekubo
FirstName LastNameBoipelo Discuss the uncertainties surrounding management
s estimates
and also how changes in the estimates would affect depreciation
expense.
Comapany NameHARMONY GOLD MINING CO LTD
March Please
8, 2024provide
Page 2 us with a draft of proposed disclosures to be included in
your future filings.
FirstName LastName
Boipelo Lekubo
FirstName LastNameBoipelo
HARMONY GOLD MININGLekubo
CO LTD
Comapany
March NameHARMONY GOLD MINING CO LTD
8, 2024
March3 8, 2024 Page 3
Page
FirstName LastName
Please contact Steve Lo at 202-551-3394 or Shannon Buskirk at
202-551-3717 if you
have questions regarding comments on the financial statements and related
matters. You may
contact John Coleman at 202-551-3610 with questions regarding the engineering
comments.
Sincerely,
Division of
Corporation Finance
Office of Energy &
Transportation
cc: Shela Mohatla