SecProbe.io

CORRESP
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Marcelo
A. Mottesi

Partner

55 Hudson Yards | New York, NY
10001-2163

T: 212.530.5602

MMOTTESI@milbank.com

December 28, 2022

Mr. Mark Wojciechowski

Mr. John Cannarella

Mr. John Coleman

Division of Corporation Finance

Office of Energy & Transportation

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-4628

Re: Buenaventura Mining Company Inc.

Form 20-F for the Fiscal Year ended
December 31, 2021, filed May 13, 2022

File No. 001-14370

Dear Mr. Wojciechowski, Mr. Cannarella, Mr. Coleman:

We note the receipt by Buenaventura
Mining Company Inc. (Compañía de Minas Buenaventura S.A.A., or the “Company”), a sociedad anónima
abierta (open stock company) under the laws of the Republic of Peru (“Peru”), of the comment letter (the “Comment
Letter”) dated November 14, 2022 from the staff (the “Staff”) of the Securities and Exchange Commission (the
 “Commission”) regarding the above-referenced Form 20-F (the “2021 20-F”). For your convenience,
we have reproduced the Staff’s comments in italics and have provided responses immediately below.

If you have any questions
or if we can provide any additional information, please do not hesitate to contact the persons listed at the end of this response letter.

SEC Comment No. 1.

Information on the Company, Page 26

We note your response to prior
comment 1 stating that you do not plan to provide any information for the Julcani and La Zanja properties in future filings because you
do not consider them to be material and have not prepared estimates of mineralization consistent with the definitions and standards in
Subpart 1300 of Regulation S-K.

However, even though you may consider
and identify the Julcani and La Zanja properties as not material, you would nevertheless need to provide the information prescribed for
summary disclosure under Item 1303 of Regulation S-K. Further, while a technical report summary is not required for a non-material property,
based on Item 1302(b) of Regulation S-K, estimates of resources and reserves must be prepared by a qualified person in accordance with
Item 1302(e) of Regulation S-K. Please submit the revisions that you propose in the form of a draft amendment to comply with the aforementioned
guidance.

December
28, 2022

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Response to SEC Comment No. 1.

The Company respectfully informs the Staff that, although it acknowledges
the guidance set forth in Item 1302(b) of Regulation S-K, it is unable to provide information regarding reserves and resources prescribed
for summary disclosure under Item 1303 of Regulation S-K in respect of the Julcani and La Zanja properties. The Company has included in
Appendix 1 hereof the Company’s proposed revisions to its 2021 20-F in respect of such properties, which address the reasons that
make it impracticable for the Company to provide investors with this information. The Company respectfully requests that these revised
disclosures be provided on a prospective basis for all future filings on Form 20-F.

SEC Comment No. 2.

We note that in response to
prior comment two you propose to include a map that appears to be an overview indicating the general location of all properties to address
Item 1303(b)(1) of Regulation S-K. However, Item 1304(b)(1)(i) of Regulation S-K requires disclosure of a property specific map for each
material property. The maps should be accurate to within one mile and based on an easily recognizable coordinate system.

We also note that you agreed
to disclose the total cost and book value of each property and its associated plant and equipment to comply with Item 1304(b)(2)(iii)
of Regulation S-K. However, we do not see these details among your proposed revisions.

Please submit a complete draft
amendment with all proposed changes marked; and include a reference to the particular page and paragraph or section where revisions appear
in response to each comment. We reissue prior comment two.

Response to SEC Comment No. 2.

The Company acknowledges the guidance set forth in Items 1304(b)(1)(i)
and 1304(b)(2)(iii) of Regulation S-K and has included in Appendix 1 and Appendix 2 hereof the Company’s proposed revisions to its
2021 20-F, in respect of the Julcani and La Zanja properties and its other mining properties, respectively, to reflect the Staff’s
comment that the Company include details regarding the total cost or book value of each property and its associated plant and equipment.
For ease of reference, such revisions in respect of the Company’s prior response in respect of disclosure set forth in Appendix
2 are shown in bold and underlined. The Company respectfully requests that these revised disclosures be provided by the
Company on a prospective basis for all future filings on Form 20-F.

SEC Comment No. 3.

We note that the revisions
you proposed in response to prior comment 3 continue to omit the point of reference in which mineral resources and reserves are presented.
For example, if mineral resources and reserves are presented as in-situ materials (prior to mining losses and processing losses), as
mill feed (after mining losses and prior to processing losses), or on some other basis, this should be evident from your disclosures.
Please comply with Item 1304(d)(1) of Regulation S-K. We reissue prior comment 3.

December
28, 2022

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Response to SEC Comment No. 3.

In response to the Staff’s request, the
Company has included in Appendix 3 hereof the Company’s proposed revisions to its 2021 20-F to reflect the Staff’s comment
that the Company disclose the point of reference with its resource and reserve tables as required by Item 1303(b)(3) and Item 1304(d)(1)
of Regulation S-K. For ease of reference, such revisions in respect of the Company’s prior response are shown in bold and
underlined. The Company respectfully requests that these revised disclosures be provided by the Company on a prospective basis
for all future filings on Form 20-F.

*               *               *

The Company acknowledges that:

 · the Company is responsible for the adequacy and accuracy of the disclosure in this filing;

 · Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with
respect to the filing; and

 · the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

If you have any questions, or require additional information please
feel free to contact me at mmottesi@milbank.com or at (212) 530-5602.

Sincerely,

/s/
Marcelo Mottesi

Marcelo
Mottesi

  cc:
  Securities and Exchange Commission:

Karl Hiller

Compañía de Minas Buenaventura S.A.A.:

Daniel Dominguez

Gulnara LaRosa

December
28, 2022

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Appendix 1: Proposed changes to 2021 20-F in
response to SEC Comment No. 1 and

SEC Comment No. 2 in respect of the Julcani
and La Zanja properties1

Proposed changes to the Company’s 2021 20-F are set forth below.

The Company will replace the section “Julcani” starting
on page 36 of the 2021 20-F, with the following:

Julcani

Location and means of access

Julcani is an underground
mine that is wholly owned and operated by us that we acquired in 1953 as our first operating mine. Julcani is located in the province
of Angaraes, in the department of Huancavelica, approximately 500 kilometers southeast of Lima at an altitude between 4,200 and 5,000
meters above sea level. There are two routes to access the mine site, both departing from Lima: (1) a first road starting in Lima
and continuing to La Oroya followed by Huancayo and Huancavelica for a total distance of 444 kilometers; and (2) a second road starting
in Lima and continuing to Pisco and then through Huancavelica which is 45 kilometers from the property for a total distance of approximately
499 kilometers.

History

The mining district of Julcani
has been known since colonial times. Between 1936 and 1945 the Swiss-Peruvian Julcani Mining Company mined the veins on an industrial
scale. The mine was then worked by the Cerro de Pasco Corporation until 1951. In 1953, the Buenaventura Mining Company was founded and
has worked the Julcani mines until today, more than 68 years later.

Title, leases and options

The Julcani mining unit,
comprises six mining concessions and one beneficiation concession (concentrator). These six concessions represent the area of mines and
exploration projects. Mining and exploration activities are carried out within these mining concessions. Julcani’s concessions have
a total area of approximately 11,566 hectares.

Mineralization

Julcani is a large polymetallic
deposit in Central Peru, which principally produces silver that presents mainly as sulpho-salts in many mineralogically complex veins.
They are hosted in dacite domes, tuffs, breccias and other tertiary volcanic rocks.

Operations and infrastructure

Ore is processed by bulk
flotation to obtain a concentrate of silver-lead-copper-gold. The plant has a rated capacity of 585 tons per day. Water for operations
in Julcani is obtained from mine drainage (that must be previously treated with lime), from seasonal streams and a small lagoon.

1
Requested to be included on a prospective basis.

December
28, 2022

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The mining method used in
this operation is cut and fill, for which the primary equipment employed are pneumatic shovels, and locomotives. The mine is currently
deepening the mine at level 710 operating with synergistic equipment such as electric shovels, jumbo jets and battery powered locomotives.

Electric power for the site
is generated by two hydroelectric plants, Huapa and El Ingenio.Power is also provided by the Peruvian national electricity grid which
Julcani is connected to.

Production

The Julcani mine is in the
production stage and has a treatment plant capacity of 500 tons of ore per day. The table below summarizes the Julcani’s mine’s
concentrate production, metal contained in concentrates produced and average grades for the periods indicated. Production in 2021 was
significantly higher than 2020 due to the higher volume of ore treated. This was primarily due to the fact that in 2020, our operations
were suspended from March until August as a result of the impact of government measures related to COVID-19.

    For the Year Ended December 31,

    2019
    2020
    2021

    Treatment ore (in tonnes)
      123,818
      71,943
      127,925

    Average ore grade

    Gold grade (g/t)
      0.09
      0.07
      0.10

    Silver grade (g/t)
      681.16
      704.98
      625.82

    Lead grade (%)
      0.86
      0.63
      0.42

    Metal contained in concentrates production

    Gold (Oz)
      150
      315
      358

    Silver (Oz)
      2,609,006
      1,676,731
      2,572,036

    Lead (t)
      966
      408
      478

    Cost applicable to sales per oz. of silver (US$/Oz-Ag)
      13.49
      14.27
      16.79

    Cost applicable to sales per ton of lead (US$/t-Pb)
      1,585
      1,126
      1,579

    Capital Expenditures (in millions of US$)
      1.6
      1.1
      2.4

Mineral Reserves and Mineral Resources

The method used to estimate
resources and reserves in the Julcani property requires the person preparing the estimation to manually determine the blocks and samples
to be used, as well as the scope of the grades to be considered for such purposes. This manual determination is made subjectively by the
applicable geologist upon visiting the property and is not based on objective parameters such as an interpretation of the vein. Additionally,
the information used by Company’s management for internal purposes is prepared on the basis of ‘relative coordinates’
that would need to be converted to The World Geodetic System 1984 standards for purposes of producing information compliant with the requirements
of Regulation S-K 1300.

These manual processes prevent
the possibility of repetition across different blocks within the property, which in turn would lead to the production of information that
would not meet the standard of “transparency” required pursuant to Regulation S-K 1300. Further, given that the scope of the
samples is not based on objective natural parameters, the Company’s calculations would likely also fail to satisfy the principle
of “materiality” underlying Regulation S-K 1300.

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28, 2022

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In light of the material
amount of resources that would be required for the Company to produce reserves and resources information that is compliant with Regulation
S-K 1300 for a property that Company management deems to be nearly depleted and immaterial when compared to the Company’s aggregate
reserves and resources disclosed elsewhere in this annual report, the Company has decided that the cost to produce such information would
outweigh its benefits and will therefore discontinue its reporting of reserves and resources in respect of the Julcani property going
forward.

The total book value for
the Julcani property and its associated plant and equipment was US$ 18.6 million as of December 31, 2021.

The Company will replace the section “La Zanja” starting
on page 554of the 2021 20-F, with the following:

La Zanja

Location and means of access

The La Zanja mine is located
in the district of Pulan, province of Santa Cruz, department of Cajamarca, 48 kilometers northwest of the Yanacocha gold mine, at an average
altitude of 3,500 meters above sea level. Access to the operation site is available through the Panamericana Norte highway from Lima to
Cajamarca followed by a departmental road network that leads to Pulán where the mining concession is located. La Zanja is operated
by us.

History

In 1990, La Zanja was part
of the northern Peru project established between Buenaventura and Newmont, covering 83,900 hectares in the Yanacocha volcanic belt by
Buenaventura Ingenieros S.A. In addition to La Zanja, other copper and gold prospects were discovered in the La Huaca, Peña Verde
and Galeno zones. In 1997, a total of 3,800 m of diamond drilling was completed at La Zanja.

After many years, in
August 2010, the Peruvian government granted permits to Buenaventura to commence metallurgical operations at La Zanja. In September of
2010, Buenaventura and Newmont began production at La Zanja. The mine was expected to produce 100,000 oz Au per year over a seven-year
mine life.

Title, leases and options

The operation area has mining
concessions assigned to La Zanja, and the surrounding area also shows the presence of other concession holders such as Buenaventura, Newmont
and several other companies. The La Zanja mining unit comprises 43 mining concessions and one beneficiation concession (concentrator).
These 43 concessions represent the area of mines and exploration projects. Mining and exploration activities are carried out within these
mining concessions. La Zanja’s concessions have an extension of approximately 27,414 hectares.

Mineralization

La Zanja is located within
a large area of hydrothermal alteration, mainly related to epithermal gold deposits in high sulphidation environments, in addition to
some bonanza Au vein epithermal systems, Cu-Au transitional epithermal-porphyry, and breccias pipe Cu-Au-Mo. We have two-ore deposits
in production in oxide material: San Pedro Sur and Pampa Verde.

December
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Operations and infrastructure

During 2021, the operation
focused on the San Pedro Sur and Pampa Verde open pits. Reinterpretation geological exploration was also carried out in projects with
resources and reserves. The operation is carried out with outsourced equipment, which includes loading equipment of 2.4–4.7 m3
and hauling equipment of 20-22 m3. The average material moved is 11.7 kilo tons per day.

Mining operations are conducted
through the open-pit method. The plant utilizes a carbon-in-column circuit as well as a Merrill-Crowe circuit to recover gold from heap
leach operations. The gold laden carbon is then t