SecProbe.io

CORRESP
 1
 filename1.htm

 Division
of Corporation Finance

 U.S.
Securities & Exchange Commission

 100
F Street, NE

 Washington,
D.C. 20549

 September
17, 2025

 Re:
Caledonia Mining Corp Plc

 Form
20-F for the Fiscal Year ended December 31, 2024

 Filed
May 16, 2025

 File
No. 001-38164

 Dear
Sir

 We
refer to your letter to Mr Ross Jerrard, Chief Financial Officer of Caledonia Mining Corporation Plc ("Caledonia"), dated
September 8, 2025 relating to Caledonia's annual report on Form 20-F for the fiscal year ended December 31, 2024 ("20-F").

 For
your convenience, your comments are included below, and we have numbered our response accordingly.

 Staff
Comment No. 1

 We
note that your table on page 39, showing mineral resources for the Blanket Mine, Bilboes Surface, Maligreen Surface, and Maligreen Underground,
includes summations on the "Grand total" line that were intended to tally inferred volumes with those of other resource categories,
though also appears to have counted twice the quantities for tonnes and contained gold of the measured and indicated resources.

 We
also note that your summation for contained gold associated with the Bilboes indicated resource in the table on page 55 appears to be
incorrect.

 Given
the limited geological evidence underlying estimates of an inferred mineral resource (as defined in Item 1300 of Regulation S-K), which
precludes the application of modifying factors in a manner that would be useful for evaluation of economic viability, we generally do
not find permissible summations of inferred resources with other categories of resources, and therefore believe that you should eliminate
such totals from the tables on pages 39, 49, and 56, consistent with the presentation guidance in Item 1303(b)(3) and Item 1304(d)(1)
of Regulation S-K.

 Caledonia's
Response:

 In
respect of the table on page 39 of the 20-F, we acknowledge that the "Grand total" row in the table was included in error,
and we acknowledge that inferred resources should not generally be added to other categories of resources.

 Registered
Office: Caledonia Mining Corporation Plc

 B006
Millais House, Castle Quay, St Helier, Jersey, Channel Islands, JE2 3EF

 info@caledoniamining.com
| | www.caledoniamining.com

 Directors:
John Kelly (Chairman), Mark Learmonth, Stefan Buys, Nick Clarke, Tariro Gadzikwa, Victor Gapare

 Lesley
Goldwasser, Geralda Wildschutt, Gordon Wylie

 We
further acknowledge that the numbers in the Grand total row in the table on page 39 are indeed erroneous and counted the underlying amounts
twice. This was a clerical error, for which we apologize, but we believe it is evident to readers as such.

 We
will ensure that grand totals adding together inferred resources to other mineral resources are not included in future annual reports
on Form 20-F.

 In
respect of the table on page 55, we acknowledge that the gold content totals for measured and indicated mineral resources at Bilboes
are incorrect. They appear to be historic ore tonnage numbers derived from a previous technical report summary and were included in error.
However, the correct totals are shown in the table on page 39 and in the initial assessment which can be found at exhibit 15.4 to the
20-F. We apologize for the clerical error and believe that the error is evident to readers as such and expect that any investor would
refer to the correct table on page 39 and in the initial assessment. We agree to fix the errors in the table in future annual reports
on Form 20-F.

 The
corrected table on page 55 (showing the corrections in strikethrough and underline) would read as follows:

 Mineral
 Resource Classification
 Orebody
 Tonnes

 Au
 Grade
 Au
 Content

 Mt

 g/t

 Koz

 Measured

 Isabella
 South
 1.325
 2.34
 100

 Isabella
 North
 2.589
 2.68
 223

 Bubi
 1.288
 1.95
 81

 McKays

 0.925
 3.05
 91

 Measured
 Total
 6.128
 2.51
 495 241

 Indicated

 Isabella
 South
 5.211
 2.17
 363

 Isabella
 North
 4.43
 2.31
 329

 Bubi
 14.006
 2.19
 987

 McKays
 3.874
 2.37
 296

 Indicated
 Total
 27.522
 2.26
 1,976 8,475

 Measured
 + Indicated Total
 33.650

 2.30
 2,470 8 ,716

 Staff
Comment No. 2

 Please
expand your disclosures to include a description of the internal controls that are used in your exploration and mineral resource and
reserve estimation efforts, as required by Item 1305 of Regulation S-K.

 Caledonia's
Response:

 In
respect of your request to expand our disclosures to include a description of the internal controls that are used in our exploration
and mineral resource and reserve estimation efforts, as required by Item 1305 of Regulation S-K, the technical reports, as referred to
and exhibited to the 20-F, include details on the methodology and validation of the mineral resource and reserve estimates. We do not
consider the absence of such disclosure in the body of the 20-F to be material and we agree to include expanded summaries of the internal
controls, derived from technical reports, in future 20-Fs.

 Whilst
we hope the above response is sufficient, if you should have any questions regarding this response letter, please do not hesitate to
contact the undersigned at AChester@caledoniamining.com or +44 7797824164.

 Sincerely

 Adam
Chester

 General
Counsel, Company Secretary and Head of Risk and Compliance

 Caledonia
Mining Corporation Plc