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Division of Corporation Finance Office of Energy and Transportation DRDGOLD Limited Form 20-F for the Fiscal Year ended June 30, 2022 Filed October 28, 2022 File No. 001-35387

Dear Mr. Coleman and Mr. Hiller:

Set forth below are the responses of DRDGOLD Limited (the

“Company”

) to the comments received from

the staff (the “

Staff

”) of the Division of Corporate Finance of the Securities and Exchange

Commission (the

“

Commission

”) by letter to Mr. Riaan Davel, dated March 2, 2023 (the

“Comment Letter”

), relating to the

Company’s Annual Report on Form 20-F for the fiscal year ended June 30, 2022 (the

“Annual Report”

).

For your convenience the text of the Staff’s Comments is set forth in bold below, followed immediately in

each case by the Company’s response. Unless otherwise indicated, all page,

graph and item number references in the

responses set forth below, are the page,

graph and item numbers of the clean copy of the Technical Report Summary.

Comment:

Form 20-F for the Fiscal Year ended June 30, 2022

Item 19 - Exhibits

Exhibit 96.1 Technical Report Summary and Certification – FWGR.

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.

U.S. Securities and Exchange Commission

April 3, 2023

Page 2

-1 000

-500

1 000

1 500

2 000

2 500

NPV10 (ZAR M)

Financial Year

Post Tax Discounted Cashflow

Cumulative Cashflow

-509

-136

-249

-499

-1 000

-500

1 000

1 500

2 000

NPV10 (ZAR M)

Financial Year

Post Tax Discounted Cashflow

Cumulative Cashflow

Company’s Response:

In response to the Staff's comment the Technical Report Summary will be revised as illustrated below, to comply with

the requirements of Item 601(b)(96)(iii)(B)(19)(ii) of Regulation S-K.

The Company proposes to add Appendix 1 to

Item 19.2 and amend the endnote below Graph 12 on page 117 of the Technical Report Summary as illustrated below.

Furthermore, numerical figures have been added to Graph 14 on page

119.

Graph 12 presents the post

-tax cashflow for

an operation that excludes

the benefits that would eventually

be derived from the Available

TSFs

(refer to

Appendix 1).

Graph 12: Post-tax Discounted Cashflows

Source:

Sound Mining, 2022

The cumulative post-tax cashflows over the

LoM remain positive. When

assuming a discount rate

of 10% the unleveraged operation

reflects a Net Present

Value

(NPV) of

ZAR2.32 Billion

with.

FWGR is

an ongoing

operation and

thus the

Internal Rate

of Return

(IRR) and

a capital

payback period

are

not

applicable.

Graph 14: Post-tax Discounted Cashflows (including liner)

Source:

Sound Mining, 2022

U.S. Securities and Exchange Commission

April 3, 2023

Page 3

Description

Unit

Total/

Average

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

FY

Reclaimed Tonnes

kt

229.371

6,044

6,044

6,044

7,546

9,048

9,048

9,048

11,148

14,400

14,400

14,400

14,400

14,400

14,400

14,400

14,400

14,400

14,400

14,400

7,000

Head Grade

g/t

0.33

0.48

0.47

0.47

0.41

0.36

0.36

0.36

0.37

0.37

0.37

0.32

0.30

0.30

0.30

0.30

0.30

0.28

0.27

0.27

0.27

Recovery

%

53%

50%

54%

57%

55%

53%

53%

53%

53%

53%

53%

51%

49%

49%

49%

54%

58%

55%

55%

55%

55%

Gold Sold

kg

40,409

1,404

1,528

1,592

1,674

1,740

1,740

1,740

2,216

2,840

2,840

2,369

2,105

2,105

2,105

2,322

2,532

2,190

2,159

2,159

1,049

Revenue

ZAR M

36,946

1,284

1,397

1,455

1,531

1,591

1,591

1,591

2,026

2,597

2,597

2,166

1,924

1,924

1,924

2,123

2,315

2,003

1,974

1,974

Operating Costs

ZAR M

19,550

1,168

1,168

1,168

1,168

1,168

1,168

1,168

1,168

1,168

1,168

1,168

Capital Expenditure

ZAR M

6,767

1,595

1,120

Post-tax Free

Cashflow

ZAR M

7,338

(678)

(199)

(397)

Cumulative Post-tax

Free Cashflow

ZAR M

7,338

(34)

1,501

2,216

2,816

3,341

3,867

4,108

4,675

5,469

6,049

6,608

7,167

7,338

Post-tax Discounted

Cashflow

ZAR M

2,318

(509)

(136)

(204)

Cumulative Post-tax

Discounted Cashflow

ZAR M

2,318

1,083

1,294

1,461

1,613

1,677

1,813

1,986

2,100

2,201

2,292

2,318

Appendix 1: Summary of the DCF Model (excluding liner)

Notes:

Apparent computational errors due to rounding

U.S. Securities and Exchange Commission

April 3, 2023

Page 4

Comment:

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.

Company’s Response:

In response to the Staff's comment, Item 25 of the Technical Report Summary will be revised as

illustrated below to comply with the requirements of Item 1302(f)(2)

of Regulation S-K, by having

the qualified persons conduct their own research where feasible and remove

non-compliant

disclosures on page 135 of the Technical Report Summary. Furthermore, the following items of the

Technical Report Summary will be amended to indicate that some information contained therein was

supplied by a third party: Items 2.3, 14, 15.1, 15.2.3,

16.1 and 17.4.

Item 25

The information and conclusions within this TRS are

based on information made available to the QPs by DRDGOLD and

FWGR at the time of

the preparation of

this TRS

as noted in

this item

. The QPs

have relied on

this information with

respect to legal

matters (Item 3),

the gold

price (Item 16.1),

Environmental

or social and labor planning aspects

Studies, Permitting, or Agreements with Locals, Individuals or Groups

(Item 17) and

the

economic

assumptions (

Assessment (

Item 19). The QPs have

not independently conducted any title or litigation searches

but have relied upon FWGR for information on the property title, agreements and other pertinent conditions (throughout Item 3).

The QPs have

reviewed this information at

face value and are

satisfied that it is

both reasonable and

appropriate.

The

QPs

consider it

believe

that it is

reasonable to rely on the information provided by FWGR

since

as identified in this item because

they are

intimately more

familiar

with the operations

and ongoing progress

of FWGR since

inception, and as a

consequence

enjoy

this provides the

QPs with

an enhanced

level of comfort with respect to

the

management

integrity and the

,

processes, procedures and quality of planning

conducted

at FWGR.

Additional information provided by FWGR included technical reports supplied by its

consultants and associates and the relevant

published

data, as listed below:

•

the QPs have not independently conducted any title

or litigation searches but have relied

upon FWGR for information on the property

title, agreements and other pertinent conditions;

•

these studies were undertaken

by Digby Wells Environmental

(South Africa) (Proprietary) Limited (Digby Wells)

and Sound Mining has

relied on the findings of these studies;

•

DRA SA

(Proprietary) Limited

were

responsible for

the detailed

design and

associated cost

estimates for

the expansion

of DP2

and

associated piping and pumping

infrastructure. Beric Robinson

Tailings (Proprietary)

Limited (Beric Robinson Tailings)

were responsible for

the design of the RTSF which

was also costed by DRA. The

QPs have relied on Spargo Consult as

an independent expert for the

review of this

work; and

U.S. Securities and Exchange Commission

April 3, 2023

Page 5

•

Geo Tail SA (Proprietary) Limited (GTSA) were responsible for the Cyclone Conversion Design and technical evaluation of the

Leeudoorn TSF; and the QPs have relied on the findings of this study.

Item 2.3

The QPs also relied on reports from:

DRA SA (Proprietary) Limited

(DRA);

Geo Tail SA (Proprietary) Limited’s (GTSA);

Beric Robinson Tailings (Proprietary) Limited (Beric Robinson Tailings); and

Digby Wells Environmental (South Africa) (Proprietary) Limited (Digby Wells).

Item 14

An expansion of the currently operating DP2 processing plant is planned to facilitate an increase in processing throughput from the

current TSF Mineral Reserve inventory.

DRA were responsible for the detailed design and associated cost estimates for the expansion of

DP2 as well as the piping and pumping infrastructure. The QPs appointed Spargo Consult, as an independent expert, to assist with the

review of the metallurgical aspects.

Item 15.1

Leeudoorn Facility

The Leeudoorn TSF is located 7km north-east of Fochville on the West Rand, Gauteng Province. Sibanye Gold have, after a detailed, joint

technical review, agreed in principle that FWGR may,

with effect from January 2026, deposit up to 500ktm of tailings onto the Leeudoorn

TSF provided FWGR paid the capital cost to convert the TSF to cyclone depositioning.

The QPs have relied on the findings of Geo Tail SA (Proprietary) Limited’s (GTSA)

Leeudoorn TSF Cyclone Conversion Design and technical

evaluation for an understanding of the planned conversion of the current day wall TSF to a cyclone-based deposition system. The design

has been developed to accommodate the required deposition plan. While the QP has not interrogated the voracity of this work in detail, it

has been benchmarked against other similar conversion projects and has been found to be within proven operational practice and

acceptable risk levels.

Item 15.2.3

Sound Mining has reviewed the

FWGR

Regional Tailings Dam Report

and design

prepared by Beric Robinson Tailings (2020)

(costed by

DRA)

and has concluded that the report provides a solid basis for the future development of a safe RTSF. Sound Mining believes that by

following the principles and design strategy outlined in the report, the chances of a TSF failure will be unlikely. However,

cognizance needs

to be taken of the uncertainties discussed subjectively below.

Item 16.1

The QP considered a five-year period of historical analysis to form an opinion of the gold price and exchange rate to be expected going

forward because the QP is of the opinion that a five-year period sufficiently covers the market volatility seen in the international gold

market. This is also consistent with the five-year period of consensus pricing relied on for the price forecast. The gold price increased in

2020 due to uncertainties related to the outbreak of Covid-19. It then steadily declined to a spot price of ~ZAR945,295/kg (i.e.,

USD1,806.89/oz at ZAR16.27/USD) as at 30 June 2022 (Graph 5).

After interrogating the gold price, the QPs are of the opinion that a gold

price of ZAR914,294/kg, provided by FWGR, is appropriate for use in the economic assessment.

U.S. Securities and Exchange Commission

April 3, 2023

Page 6

Item 17.4

Environmental Closure Liability Estimate

Sound Mining

has

relied on

environmental

closure liability

estimates

provided

by

Digby

Wells.

They

are

experts in

this field

and

were

commissioned for the purpose

. A review of the closure estimate and associated plans

covered

the following aspects:

•

discussion of the methodology used to derive the costs for demolition, closure and rehabilitation; and

•

comment on the adequacy of the financial provisions made for the operation.

*

*

*

Should the Staff have any questions or comments, please contact me on +27 11 470

2600 or at riaan.davel@drdgold.com.

Sincerely,
/s/ Riaan Davel