SEC Comment Letter 0000000000-23-002104 to DRDGOLD LTD (DRD, DRDGF) (CIK 0001023512) (DRD)
DRDGOLD LTD (DRD, DRDGF) (CIK 0001023512)
Date: March 2, 2023 · CIK: 0001023512 · Accession: 0000000000-23-002104
AI Filing Summary & Sentiment
File numbers found in text: 001-35387
Letter
United States securities and exchange commission logo March 2, 2023 Riaan Davel Chief Financial Officer DRDGOLD LIMITED Constantia Office Park Cnr 14th Avenue and Hendrik Potgieter Road Cycad House, Building 17, Ground Floor Weltevreden Park 1709 South Africa Re:DRDGOLD LIMITED Form 20-F for the Fiscal Year ended June 30, 2022 Filed October 28, 2022 File No. 001-35387 Dear Riaan Davel: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 20-F for the Fiscal Year ended June 30, 2022 Item 19 - Exhibits Exhibit 96.1 Technical Report Summary and Certification - FWGR, page 3 1.We note that disclosures under Economic Assessment, on pages 117 and 119 of the Technical Report Summary, include graphs illustrating gold sales quantities and life-of- mine cash flows although without distinct numerical or line item details.
Please discuss this observation with the qualified persons and arrange to obtain and file a revised Technical Report Summary that includes the entire discounted cash flow analysis, including annual cash flow forecasts based on an annual production schedule for the life of project, to comply with Item 601(b)(96)(iii)(B)(19)(ii) of Regulation S-K.
FirstName LastNameRiaan Davel Comapany NameDRDGOLD LIMITED March 2, 2023 Page 2 FirstName LastName Riaan Davel DRDGOLD LIMITED March 2, 2023 Page 2 2.We note that disclosures under Reliance on Information Provided by the Registrant, on page 136 of the Technical Report Summary, include categories of information beyond those that are permissible under Item 1302(f)(1) of Regulation S-K.
For example, in the last two bullet points of this section, the qualified persons indicate there has been reliance with regard to certain cost estimates and technical evaluations provided by FWGR or its consultants or associates.
Please discuss this observation with the qualified persons and arrange to obtain and file a revised Technical Report Summary that is consistent with the requirements in Item 1302(f)(2) of Regulation S-K.
We generally anticipate that qualified persons would validate and discuss information utilized in preparing the report that is not within the categories listed in the guidance referenced above, in an alternate and corresponding section of the report.
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 John Coleman, Mining Engineer, as (202) 551-3610, with any questions regarding the mineral property disclosures. You may contact Karl Hiller, Branch Chief, at (202) 551-3686 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
March 2, 2023
Riaan Davel
Chief Financial Officer
DRDGOLD LIMITED
Constantia Office Park
Cnr 14th Avenue and Hendrik Potgieter Road
Cycad House, Building 17, Ground Floor
Weltevreden Park 1709
South Africa
Re:DRDGOLD LIMITED
Form 20-F for the Fiscal Year ended June 30, 2022
Filed October 28, 2022
File No. 001-35387
Dear Riaan Davel:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year ended June 30, 2022
Item 19 - Exhibits
Exhibit 96.1 Technical Report Summary and Certification - FWGR, page 3
1.We note that disclosures under Economic Assessment, on pages 117 and 119 of the
Technical Report Summary, include graphs illustrating gold sales quantities and life-of-
mine cash flows although without distinct numerical or line item details.
Please discuss this observation with the qualified persons and arrange to obtain and file a
revised Technical Report Summary that includes the entire discounted cash flow
analysis, including annual cash flow forecasts based on an annual production schedule for
the life of project, to comply with Item 601(b)(96)(iii)(B)(19)(ii) of Regulation S-K.
FirstName LastNameRiaan Davel
Comapany NameDRDGOLD LIMITED
March 2, 2023 Page 2
FirstName LastName
Riaan Davel
DRDGOLD LIMITED
March 2, 2023
Page 2
2.We note that disclosures under Reliance on Information Provided by the Registrant, on
page 136 of the Technical Report Summary, include categories of information beyond
those that are permissible under Item 1302(f)(1) of Regulation S-K.
For example, in the last two bullet points of this section, the qualified persons indicate
there has been reliance with regard to certain cost estimates and technical evaluations
provided by FWGR or its consultants or associates.
Please discuss this observation with the qualified persons and arrange to obtain and file a
revised Technical Report Summary that is consistent with the requirements in Item
1302(f)(2) of Regulation S-K.
We generally anticipate that qualified persons would validate and discuss information
utilized in preparing the report that is not within the categories listed in the guidance
referenced above, in an alternate and corresponding section of the report.
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 John Coleman, Mining Engineer, as (202) 551-3610, with any questions
regarding the mineral property disclosures. You may contact Karl Hiller, Branch Chief, at (202)
551-3686 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation