United States securities and exchange commission logo
January 19, 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
Filed October 31,
2023
File No. 001-31545
Dear Boipelo Lekubo:
We have limited our review of your filing to the financial
statements and related
disclosures 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.
Form 20-F For the Fiscal Year Ended June 30, 2023
Item 16F. Change in Registrant's Certifying Accountant, page 182
1. Please revise to state
whether you consulted your new independent principal accountants,
Ernst & Young, Inc.,
during the two most recent fiscal years or any subsequent interim
period and provide
required disclosures pursuant to Item 16F(a)(2) of Form 20-F.
Item 19. Exhibits
96.12 Technical Report Summary of the Mineral Resources and Mineral
Reserves for Tshepong
North, Free State Province, South Africa, page 189
2. We note that the gold
recovered in your life of mine plan exceeds the gold content
disclosed in your
mineral reserve table. For example the gold recovered listed in Table
19.4 is 24,789 kg,
which is greater than the gold content of 18,731 kg listed in Table 12-4.
Please explain these
differences. To the extent materials other than reserves have been
included in your life
of mine plan and cash flow analysis, please tell us the nature of these
Boipelo Lekubo
FirstName LastNameBoipelo
HARMONY GOLD MININGLekubo
CO LTD
Comapany
January 19,NameHARMONY
2024 GOLD MINING CO LTD
January
Page 2 19, 2024 Page 2
FirstName LastName
materials. Only mineral reserves should be included in the cash flow
analysis of a
preliminary feasibility study or feasibility study, in order to meet
the requirements of Item
1302(e)(3) of Regulation S-K, and the definition of a mineral reserve
under Item 1300 of
Regulation S-K.
3. Please tell us if capital costs and the extent to which closing costs
have been included in
the Tshepong North cash flow analysis. Additionally, please reconcile
the
difference between the Total Operating Cost line item in Table 19-4,
and the Summary of
Operating Cost Estimate for Tshepong North in Table 18-2.
Exhibit 99.1
Notes to the Group Financial Statements
15. Property, Plant and Equipment
Depreciation, page F-33
4. Your accounting policy appears to indicate you include inferred
resources into the unit-of-
production calculation for determining the amount of depreciation of
your mining assets,
when you have confidence that such inferred resources will be
converted into reserves. In
order to enhance our understanding of your accounting policy, please
address the
following points:
Tell us the percentage and amount of inferred resources that
you include in the
portion of mineralization expected to be classified as reserves;
Provide us with your history of converting inferred resources
into proven and
probable reserves;
Tell us the number of years of historical data that you have
used to estimate your
projected rates of converting inferred resources to proven and
probable reserves;
Explain to us whether or not and why historical trends are
indicative of future
conversion rates;
If you have a consistent track record of converting inferred
resources to proven and
probable reserves, please explain the reasons for your success,
given that the
information you have about resources is significantly less than
the information and
supporting technical data that you have about proven and probable
reserves; and
Tell us to the extent which resources are currently accessible
and the extent which
additional capital improvements are required to convert and gain
access to inferred
resources.
5. To better understand the effect of resources on your depletion
expense, please provide us
with the amount of depletion expense for each period presented if (i)
only proven and
Boipelo Lekubo
HARMONY GOLD MINING CO LTD
January 19, 2024
Page 3
probable reserves is included in the depreciable base (i.e., excluding
all measured and
indicated and all inferred mineral resources from the depreciable base)
and only proven
and probable reserves plus the portion of measured and indicated
resources expected to be
converted to mineral reserves (i.e., excluding all inferred mineral
resources from
the depreciable base).
In closing, 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.
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
January 19, 2024 Page 3
cc: Shela Mohatla
FirstName LastName