SEC Comment Letter 0000000000-24-002579 to HARMONY GOLD MINING CO LTD (HMY)
HARMONY GOLD MINING CO LTD
Date: March 8, 2024 · CIK: 0001023514 · Accession: 0000000000-24-002579
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File numbers found in text: 001-31545
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United States securities and exchange commission logo
March 8, 2024
Boipelo Lekubo
Financial Director
HARMONY GOLD MINING CO LTD
Randfontein Office Park
CNR Ward Avenue and Main Reef Road
Randfontein, South Africa 1759
Re:HARMONY GOLD MINING CO LTD
Form 20-F For the Fiscal Year Ended June 30, 2023
Response dated February 20, 2024
File No. 001-31545
Dear Boipelo Lekubo:
We have reviewed your February 20, 2024 response to our comment letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our January 19,
2024 letter.
Form 20-F For the Fiscal Year Ended June 30, 2023
96.12 Technical Report Summary of the Mineral Resources and Mineral Reserves for Tshepong
North, Free State Province, South Africa, page 189
1.We note your response to comment 2. The provisions in S-K 1300 preclude the inclusion
of inferred resources in an economic analysis that supports a property's economic
viability. For example, pursuant to Item 1302(e)(6) of Regulation S-K, a qualified person
must exclude inferred mineral resources from a pre-feasibility study's demonstration of
economic viability in support of a disclosure of a mineral reserve. Please obtain and file a
revised Tshepong North technical report summary from your qualified person to comply
with this requirement. Please review your other technical report summaries and make
arrangements with your respective qualified persons to revise as necessary to comply with
this requirement.
FirstName LastNameBoipelo Lekubo
Comapany NameHARMONY GOLD MINING CO LTD
March 8, 2024 Page 2
FirstName LastName
Boipelo Lekubo
HARMONY GOLD MINING CO LTD
March 8, 2024
Page 2
Exhibit 99.1
Notes to the Group Financial Statements
15 Property, Plant and Equipment
Depreciation, page F-33
2.Please revise your future filings to provide a critical accounting policy for depreciation
that addresses your method of depreciating mining-related assets. Please address the
following items:
•Define each of proven and probable reserves, measured and indicated resources and
inferred 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
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;
•Disclose the amounts and percentages of variances between the amount of
depreciation calculated including these resources and the amount of depreciation
calculated without these resources;
•Describe how you risk weighted the resources included in the depreciation
calculation; or if you do not risk 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 estimates
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.
FirstName LastNameBoipelo Lekubo
Comapany NameHARMONY GOLD MINING CO LTD
March 8, 2024 Page 3
FirstName LastName
Boipelo Lekubo
HARMONY GOLD MINING CO LTD
March 8, 2024
Page 3
Please contact Steve Lo at 202-551-3394 or Shannon Buskirk at 202-551-3717 if you
have questions regarding comments on the financial statements and related matters. You may
contact John Coleman at 202-551-3610 with questions regarding the engineering comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Shela Mohatla