SEC Comment Letter for HARMONY GOLD MINING CO LTD (HMY, HGMCF) (CIK 0001023514) (HMY) — Jan 31, 2017
HARMONY GOLD MINING CO LTD (HMY, HGMCF) (CIK 0001023514)
Date: Jan. 31, 2017 · CIK: 0001023514 · Accession: 0000000000-17-003371
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 January 31, 2017 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, 17 59
Re: Harmony Gold Mining Company Limited Form 20 -F for the Fiscal Year Ended June 30, 201 6 Filed October 2 6, 201 6 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you wi ll respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year End ed June 30, 2016 Exhibit 99.33 General
1. We note your disclosure of mineral resources on pages 6, 111, 113, and 114 of your integrated annual report. Only proven and probable reserves may be disclosed in filings with the United States Securities and Exchan ge Commission. Please remove these mineral resources.
2. Please tell us if the financial metrics related to your Golpu feasibility study on pages 115, 116, and 119 of your annual report are before tax numbers or after tax numbers and clarify the disclosure .
Frank Abbott Harmony Gold Mining Company Limited January 31 , 2017 Page 2
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact John Coleman at (202) 551 -3610 or me at (202) 551 -3790 with any questions. Sincerely ,
/s/ John Reynolds
John Reynolds Assistant Director Offices of Beverages, Apparel and Mining
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Mail Stop 3561 January 31, 2017 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, 17 59 Re: Harmony Gold Mining Company Limited Form 20 -F for the Fiscal Year Ended June 30, 201 6 Filed October 2 6, 201 6 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you wi ll respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 20-F for the Fiscal Year End ed June 30, 2016 Exhibit 99.33 General 1. We note your disclosure of mineral resources on pages 6, 111, 113, and 114 of your integrated annual report. Only proven and probable reserves may be disclosed in filings with the United States Securities and Exchan ge Commission. Please remove these mineral resources. 2. Please tell us if the financial metrics related to your Golpu feasibility study on pages 115, 116, and 119 of your annual report are before tax numbers or after tax numbers and clarify the disclosure . Frank Abbott Harmony Gold Mining Company Limited January 31 , 2017 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact John Coleman at (202) 551 -3610 or me at (202) 551 -3790 with any questions. Sincerely , /s/ John Reynolds John Reynolds Assistant Director Offices of Beverages, Apparel and Mining