SecProbe.io

March 9, 2020
Adriaan Davel
Chief Financial Officer
DRDGOLD LTD
1 Sixty Jan Smuts Building
2nd Floor-North Tower
160 Jan Smuts Avenue
Rosebank, 2196
South Africa
Re:DRDGOLD LTD
Form 20-F for the Fiscal Year ended June 30, 2019
Filed October 31, 2019
File No. 001-35387
Dear Mr. Davel:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year ended June 30, 2019
Financial Statements
Note 26 - Contingent Assets and Liabilities
Ekurhuleni Metropolitan Municipality ("Municipality") Electricity Tariff Dispute, page 124
1.We note you are currently engaged in a legal dispute with Ekurhuleni Metropolitan
Municipality (Municipality) relating to tariffs they have charged for electricity supplied by
ESKOM Holdings SOC Limited.  We understand that in December of 2014 you began
depositing the disputed tariffs into a trust account rather than paying the Municipality, and
that this practice continued until January 2018, when you were required to pay the tariffs
held in arrears to the Municipality, in advance of settling the dispute.  Further, we note
that in 2018 you began accounting for the disputed portion of the tariffs differently, by

 FirstName LastNameAdriaan Davel
 Comapany NameDRDGOLD LTD
 March 9, 2020 Page 2
 FirstName LastName
Adriaan Davel
DRDGOLD LTD
March 9, 2020
Page 2
recording the disputed portion of the payments as an asset on a discounted basis.

Please provide us with a roll-forward schedule covering each period and all disputed
tariffs to illustrate the effects of your accounting in the financial statements.  Please
indicate the fiscal periods to which the amounts are attributable according to the
Municipality, as well as the expense recognized, extent of any payments, amounts you are
seeking to recover, and any provisions recognized in accordance with IAS 37.

Please reconcile these details with the information you have disclosed in Notes 13, 22, 25
and 26 of the financial statements and tell us how you considered paragraphs 31 through
35 of IAS 37 in recognizing the asset, Payments made under protest.
            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.
            You may contact Mark Wojciechowski, Staff Accountant, at (202) 551-3759 or Jenifer
Gallagher, Staff Accountant, at (202) 551-3706 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation