SEC Comment Letter for HARMONY GOLD MINING CO LTD (HMY, HGMCF) (CIK 0001023514) (HMY) — Feb 6, 2020
HARMONY GOLD MINING CO LTD (HMY, HGMCF) (CIK 0001023514)
Date: Feb. 6, 2020 · CIK: 0001023514 · Accession: 0000000000-20-001177
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File numbers found in text: 001-31545
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February 6, 2020
Frank Abbott
Chief Financial Officer
Harmony Gold Mining Company Limited
Randfontein Office Park
CNR Ward Avenue and Main Reed Road
Randfontein, South Africa, 1759
Re:Harmony Gold Mining Company Limited
Form 20-F for Fiscal Year Ended June 30, 2019
Filed October 24, 2019
File No. 001-31545
Dear Mr. Abbott:
We have reviewed your filing and 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 business days by providing the requested
information or advise us as soon as possible when you will 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 Fiscal Year Ended June 30, 2019
Item 4. Information on the Company
B. Business Overview, page 26
1.We note the disclosure of mineral reserves on page 29 of your filing. Please revise to
disclose the metallurgical recovery factor for each of your mineral reserves.
D. Property, Plant and Equipment., page 44
2.Please revise to provide an overview for each of your significant properties pursuant to
Item 102 of Regulation S-K and the guidance in paragraph (b) of Industry Guide 7. It
appears that this type of disclosure for your mining operations was provided in your Form
20-F for the fiscal year ended June 30, 2018, but is not included in your filing for the
fiscal year ended June 30, 2019.
FirstName LastNameFrank Abbott
Comapany NameHarmony Gold Mining Company Limited
February 6, 2020 Page 2
FirstName LastName
Frank Abbott
Harmony Gold Mining Company Limited
February 6, 2020
Page 2
Exhibit 15.1, page 63
3.We note the disclosure of mineral resources in your filing, including on pages 63 and 66
of your integrated annual report. Only proven and probable reserves may be disclosed in
filings with the United States Securities and Exchange Commission pursuant to the
Instructions to paragraph (b)(5) of Industry Guide 7. Please revise to remove
the disclosure of mineral resources.
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.
You may contact John Coleman at 202-551-3610 or Ethan Horowitz at 202-551-3311 if
you have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation