SEC Comment Letter for HARMONY GOLD MINING CO LTD (HMY, HGMCF) (CIK 0001023514) (HMY) — Sep 28, 2011
HARMONY GOLD MINING CO LTD (HMY, HGMCF) (CIK 0001023514)
Date: Sept. 28, 2011 · CIK: 0001023514 · Accession: 0000000000-11-057696
AI Filing Summary & Sentiment
Referenced dates: July 21, 2011, May 11, 2011
Letter
September 28, 2011 Via E-mail Mr. Graham Briggs Chief Executive Officer Harmony Gold Mining Company Limited Randfontein Office Park CNR Ward Avenue and Main Reef Road Randfontein, South Africa, 1760 Re: Harmony Gold Mining Company Limited Form 20-F for Fiscal Year Ended June 30, 2010 Filed October 25, 2010 Response Letter Dated May 11, 2011 Response Letter Dated July 21, 2011 File No. 1-31545
Dear Mr. Briggs: We have reviewed your response letter 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 this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments. Form 20-F for Fiscal Year Ended June 30, 2010
1. We note your response to our previous commen t number 4. In regards to your Rolspruit and Poplar reserves we reference stat ements in your February 26, 2010 competent persons report that was provided to the Co mmission. Section 21.2.3 of this report states that there is insufficient back up for the cal culations done to estimate Mineral Resources and that SRK considers the classification of Indicated at Poplar to be optimistic when compared to surrounding projects. In additi on we note the recommendations made in the report in Sections 22.2.3 and 22.3. Consideri ng these statements and recommendations it appears that your Rolspruit and Poplar re serves may not meet the Industry Guide 7 reserve requirements. Please advise.
Mr. Graham Briggs Harmony Gold Mining Company Limited September 28, 2011 Page 2
Closing Comments
You may contact John Cannarella at (202) 551-3337 or Mark Wojciechowski at (202) 551-3759 if you have questions regarding comments on the financial statements and related matters. You may contact John Coleman, Mi ning Engineer, at (202) 551-610 with any engineering questions. Please contact me at (202) 551-3489 with any other questions. S i n c e r e l y , / s / B r a d S k i n n e r B r a d S k i n n e r Senior Assistant Chief Accountant
Show Raw Text
September 28, 2011
Via E-mail
Mr. Graham Briggs Chief Executive Officer Harmony Gold Mining Company Limited Randfontein Office Park CNR Ward Avenue and Main Reef Road Randfontein, South Africa, 1760
Re: Harmony Gold Mining Company Limited
Form 20-F for Fiscal Year Ended June 30, 2010
Filed October 25, 2010 Response Letter Dated May 11, 2011 Response Letter Dated July 21, 2011 File No. 1-31545
Dear Mr. Briggs:
We have reviewed your response letter 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
Form 20-F for Fiscal Year Ended June 30, 2010
1. We note your response to our previous commen t number 4. In regards to your Rolspruit
and Poplar reserves we reference stat ements in your February 26, 2010 competent
persons report that was provided to the Co mmission. Section 21.2.3 of this report states
that there is insufficient back up for the cal culations done to estimate Mineral Resources
and that SRK considers the classification of Indicated at Poplar to be optimistic when
compared to surrounding projects. In additi on we note the recommendations made in the
report in Sections 22.2.3 and 22.3. Consideri ng these statements and recommendations it
appears that your Rolspruit and Poplar re serves may not meet the Industry Guide 7
reserve requirements. Please advise.
Mr. Graham Briggs Harmony Gold Mining Company Limited September 28, 2011 Page 2
Closing Comments
You may contact John Cannarella at (202) 551-3337 or Mark Wojciechowski at (202)
551-3759 if you have questions regarding comments on the financial statements and related
matters. You may contact John Coleman, Mi ning Engineer, at (202) 551-610 with any
engineering questions. Please contact me at (202) 551-3489 with any other questions.
S i n c e r e l y , / s / B r a d S k i n n e r B r a d S k i n n e r Senior Assistant Chief Accountant