SecProbe.io

February 27, 2013

Via E-mail
Frank Abbott
Chief Financial 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, 2012
Filed October 29, 2012
File No. 001 -31545

Dear Mr. Abbott :

We have reviewed your filing an d 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 advising us when you will provide the reques ted
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 2 0-F for Fiscal Year Ended June 30, 2012

Item 4. Information on the Company, page 19
Harmony’s Mining Operations, page 31

1. We note several mines (e.g. Bambanani , Target operation, etc.) produced ounces of gold
prior to the mine being in the production stage.  We also note that revenue  receiv ed from
such pre -production was  credited to capital expenditures each period.  Please confirm in
future filings you will rev ise your disclosure to quantify the dollar impact of such
proceeds to your capital expenditures.  Please provide us with draft discl osure of your
planned changes.

Frank Abbott
Harmony Gold Mining Company Limited
February 27, 2013
Page 2

 Item 5. Operating and Financial Review and Prospects, page 82
Results of Operations , page 90
b) Depreciation and amortization, page 92

2. We note that your depreciation and amortization expenses increased $17 million in fiscal
year 2012 when your proven and probable reserves increased from 41.6 million ounces in
2011 to 52.9 million ounces in 2012 and your gold production decreased from 1.195
million ounces in 2011 to 1.165 million ounces in 2012.  Please provide us with, and
confirm to us that you will include in future filings, a detailed explanation for the increase
in your depreciation and amort ization expenses between the periods .

Item 18. Consolidated Financial Statements
Notes to the Consolidated Financial Statements , page F -8
2 Accounting policies , page F -8
2.5 (vi) Depreciation and amortization of mining assets, page F -12

3. Your accounting policy indicates that, in some instances, you include mineral resources
other than the proven and probable reserves in the unit -of-production calculation for
determining the depreciation and amortization of your mining assets, when management
has high leve l of confidence that such further resources will be converted into reserves.
To enhance our understanding of your accounting policy, please:

 Tell us the percentage and amount of measured, indicated and inferred  resources that
you include in the portion o f mineralization expected to be classified as reserves, and
tell us whether there have been any changes to your policy; and
 Provide us with your history of converting resources into proven and probable
reserves.
 Tell us the number of years of historical da ta that you have used to estimate you r
projected rates of converting  resources to proven and probable reserves.
 Explain to us whether or not and why historical trends are indicat ive of future
conversion rates.
 If you have a consistent track record of conve rting resources to proven and probable
reserves, please explain the reasons for your success, given that the information you
have about resources is significantly less than the information and supporting
technical data that you have about proven and probab le reserves.
 Tell us the extent to which resources are currently accessible and the extent to which
additional capital improvements are required to convert and gain access to resources.

4. Please explain to us why and how you determined that your estimate s of resources, such
as inferred mineral resources, used to calculate your units of production depreciation are
reliable, as contemplated by paragraph 4.41 of the Conceptual Framework for Financial
Reporting issued by the International Accounting Standards  Board.

Frank Abbott
Harmony Gold Mining Company Limited
February 27, 2013
Page 3

 5. To better understand the  effect  of resources on your depletion expense, please provide us
with the amount of depletion expense for each period presented if (i) only proven and
probable reserves is included  in the depreciable base (i.e., excluding all measured and
indicated and all inferred mineral resou rces from the depreciable base) and only proven
and probable reserves plus the portion of measured and indicated resources  expected to
be converted to mineral reserves (i.e., excluding all inferred m ineral resour ces from the
depreciable base).

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the 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.

You may contact Suying Li  at (202) 551 -3335 or Brian Bhandari, Branch Chief,  at (202)
551-3390  if you have questions regarding comments on the financial statements and related
matters.

Sincerely,

/s/Tia L . Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining