United States securities and exchange commission logo
April 18, 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
April 8, 2024
File No. 001-31545
Dear Boipelo Lekubo:
We have reviewed your April 8, 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 March 8,
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. In response to comment
1 we note you propose to include two separate cash flows
in the Tshepong North
Technical Report Summary; one cash flow includes inferred
mineral resources and
one cash flow is based solely on mineral reserves. In order to
satisfy the
requirements of Item 1302(e)(6) of Regulation S-K, inferred resources cannot
be included in a
pre-feasibility study or feasibility study cash flow. Therefore the cash
flow that includes
inferred resources should be removed from the Tshepng North technical
report summary.
Item 1302(e)(5) of
Regulation S-K requires a pre-feasibility study to include an economic
Boipelo Lekubo
HARMONY GOLD MINING CO LTD
April 18, 2024
Page 2
analysis that supports the property's economic viability as assessed by a
detailed
discounted cash flow analysis or other similar financial analysis. In the
absence of a
discounted cash flow analysis or similar financial analysis that supports
the economic
viability of the Tshepong North mineral reserve, we would expect you to
revise your
annual filing to remove the Tshepong North mineral reserve and related
disclosures. To
the extent the elimination of the reserve materially impacts the
depletion amounts
recorded in your financial statements, please analyze these impacts and
revise your
financial disclosures as necessary.
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,
FirstName LastNameBoipelo Lekubo
Division of
Corporation Finance
Comapany NameHARMONY GOLD MINING CO LTD
Office of Energy &
Transportation
April 18, 2024 Page 2
cc: Shela Mohatla
FirstName LastName