SecProbe.io

April 23, 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
Response dated April 5, 2013
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 requested
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
Financial Statements
Notes to the Consolidated Financial Statements
2 Accounting policies
2.5 (vi) Depre ciation and amortization of mining assets, page F -12

1. We reviewed your response to prior comments 3 and 5.   Please provide the following
information related to your Doornkop South Reef and Masimong mines.

 Please supplement for us your reconciliation of pr oven and probable reserves for the
three years ended June 30, 2012 with a rollforward for each year  showing reserves
consumed and those converted from resources.

Frank Abbott
Harmony Gold Mining Company Limited
April 23, 2013
Page 2

  Please provide PDF copies of the maps for your Doornkop South Reef mine as of
June 30, 2011 an d June 30, 2010 along with the reserve/resource information and the
mine plan panels or stope outline similar to your  Maps 1(a) and 1 (b) as provided
previously.

 Please provide PDF copies of the maps for your Masimong mine with the
superimposed life of m ine plan panels or stope outline and the reserve/resource
information at the end of each of the last three fiscal years in the period ended June
30, 2012 as included in the Map 2(a), but of the same general area and scale.

2. We reviewed your response to our  prior comment 3, noting your depreciable base
includes both capitalized costs as well as future development costs necessary to access
reserves and inferred resources at the Doornkop South Reef and Masimong mines.
Considering access of such reserves and r esources occurs over time, tell us how your
depreciation calculation allocates the depreciable base between the portion currently in
use versus the portion not in use.   For guidance, refer to paragraphs 43 through 45 of IAS
16.

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 the disclosures they have made.

You may contact Suying Li  at (202) 551 -3335 or Brian Bhandari, Branch Chief,  at (202)
551-3390  if you hav e 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