SecProbe.io

July 3, 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 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 20 -F for Fiscal Year Ended June 30, 2012

Item 5. Operating and Financial Review and Prospects
Critical Accounting Policies and Estimates, page 83

1. Please revise your future filings to provide a critical accounting policy  that addresses
your method of depreciating mining -related assets.   Please address the following items:

 Define your accounting policy, define each of proven and probable reserves,
measured and indicated resources and in ferred resources.
 Describe the circumstances under which each type of “resource” is included in the
calculation of depreciation, describe management’s assumptions concerning these
resources (i.e., circumstances under which the resources may be economically  mined,
additional timing and work to convert the resources to reserves, gold pricing

Frank Abbott
Harmony Gold Mining Company Limited
July 3, 2013
Page 2

 concerns, etc.), and describe management’s track record regarding the conversion of
resources to reserves.
 Disclose the nature and amount of resources that are included in the depreciation
calculation for each year for which an income statement is presented.
 Describe how you risk -weighted the resources included in the depreciation
calculation; if you do not r isk-weight those quantities, explain why.
 Disclose whether additional development costs are also included in the calculation of
depreciation and how those costs are determined.   If so, disclose  the amount of
additional development costs that were included  in the depreciation calculation for
each year for which an income statement is presented.
 Provide all of the requested disclosures on an overall basis and on a mine -by-mine
basis as necessary.   Discuss the uncertainties surrounding management’s estimate s
and also how changes in the estimates would affect depreciation expense.
Please provide us with a draft of proposed disclosures to be included in your future
filings.

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

2. Please expand this note in your future filings to address the following items:

 Describe the specific nature of the resources that are included in the depreciation
calculation.
 Describe the nature of the historical experience and available geological information
that permit management to conclude with a high degree of confidence that the
resources are economically recoverable.
 Discuss the nature and amount of development costs  that are included in the
depreciation calculation.   Describe how these costs are determined.
 Disclose the amount of depreciation and amortization expense of mining assets for
each period presented with and without the inclusion of resources in the denomi nator
and future development costs in the numer ator.
Please provide us with a draft of proposed disclosures to be included in your future
filings.

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 respons ible for the accuracy
and adequacy of the disclosures they have made.

Frank Abbott
Harmony Gold Mining Company Limited
July 3, 2013
Page 3

 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