SecProbe.io

February 19 , 2014

Via E -Mail
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  the Fiscal Year Ended June 30, 2013
Filed October 25, 2013
File No. 001-31545

Dear Mr. Briggs :

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 req uested
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 i n
response to these  comments, we may have  additional comments.

Form 20 -F for the Fiscal  Year Ended June 30, 2013

General

1. You disclose that your fiscal year end is June 30.  Please also include your current
fiscal year end in  the Company Data se ction of EDGAR.

Graham Briggs
Harmony Gold Mining Company Limited
February 19 , 2014
Page 2

Reserves , page 26

2. Please forward to our engineer as supplemental information and not as part of your filing,
your Wafi -Golpu project technical report  that establishes the legal, technical, and
economic feasibility of your materials desig nated as reserves, as required by paragraph
(c) of Industry Guide 7 .  The information requested includes, but is not limited to:

 Property and geologic maps
 Description of your sampling and assaying procedures

 Drill -hole maps showing drill intercepts

 Representative geologic cross -sections and drill logs

 Description and examples of your cut -off calculation procedures

 Cutoff grades used for each category of your reserves and resources

 Justifications for the drill hole spacing used to classify and segr egate proven and
probable reserves

 A detailed description of your procedures for estimating reserves

 Copies of any pertinent engineering or geological reports, and executive summaries
of  feasibility studies or mine plans which including the cash flow an alyses

 A detailed permitting and government approval schedule for the project, particularly
identifying the primary environmental or construction approval(s) and your current
location on that schedule.

Please provide this information on a CD, formatted a s Adobe PDF files.  Please also
provide the name and phone number for a technical person whom our engineer may call
if he has technical questions about your reserves.  You may ask to have this information
returned by making a written request at the time it  is furnished, as provided in Rule 12b -4
of Regulation 12B.  If you have questions concerning the above request, please contact
John Coleman, Mining Engineer at (202) 551 -3610.

Graham Briggs
Harmony Gold Mining Company Limited
February 19 , 2014
Page 3

 Financial Statements

Report of Independent Registered Public Accounting Firm , page F -2

3. We note the date of the audit report, October 25, 2012, precedes the date of the financial
statements referenced in the audit report, June 30, 2013.   Please advise your independent
accountant to revise its report to address this  apparent inconsistency  and amend your
Form 20 -F accordingly.

Notes to the Consolidated Financial Statements
2. Accounting Policies , page F -8
2.3 Revenue Recognition, page F -12

4. We note your revenue recognition policy appears to be a summary of IAS 18
paragraph 14.  To enhance investors ’ understand ing of your revenue recognition
requirements, please provide us with and confirm that  in future filings you will
revise to expand your accounting policy  in a manner that is  tailored to  specific
information  relating  to your revenue generating activities .

Other

5. We note you indicate on your website under the results for the second quarter ended
December 31, 2013 under the caption “Harmony continues to generate profits despite
lower production” that  Operating profit for the December 2013 quarter was 5% lower
than in the previous quarter at R986 million (US$97 million).  However, it does not
appear you generated a profit under IFRS for either the three or six month period ended
December 31, 2013.  It appears your reference to positive “operating profit” is based on
the term “production profit” per the segment report provided in the segment footnote.
Considering your operating loss as presented in your financial statements for three or six
month period ended December 31, 2013, it appears to us appropriately labeling this
measure (e.g., “production profit”) with definition  of the  term and revisi on of the caption
and the contents would add clarity and enhance investor s’ understanding of your
business. Please advise.

We urge all persons who are responsible for the accur acy 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.

Graham Briggs
Harmony Gold Mining Company Limited
February 19 , 2014
Page 4

 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 Jamie Kessel  at 202-551-3727 or Raj Rajan  at 202-551-3388 if you
have any questions.

Sincerely,

/s/Tia L. Jenkins

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