SEC Comment Letter 0000000000-24-004282 to HARMONY GOLD MINING CO LTD (HMY)
HARMONY GOLD MINING CO LTD
Date: April 18, 2024 · CIK: 0001023514 · Accession: 0000000000-24-004282
AI Filing Summary & Sentiment
File numbers found in text: 001-31545
Letter
United States securities and exchange commission logo April 18, 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 April 8, 2024 File No. 001-31545 Dear Boipelo Lekubo: We have reviewed your April 8, 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 March 8, 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.In response to comment 1 we note you propose to include two separate cash flows in the Tshepong North Technical Report Summary; one cash flow includes inferred mineral resources and one cash flow is based solely on mineral reserves. In order to satisfy the requirements of Item 1302(e)(6) of Regulation S-K, inferred resources cannot be included in a pre-feasibility study or feasibility study cash flow. Therefore the cash flow that includes inferred resources should be removed from the Tshepng North technical report summary.
Item 1302(e)(5) of Regulation S-K requires a pre-feasibility study to include an economic
FirstName LastNameBoipelo Lekubo Comapany NameHARMONY GOLD MINING CO LTD April 18, 2024 Page 2 FirstName LastName Boipelo Lekubo HARMONY GOLD MINING CO LTD April 18, 2024 Page 2 analysis that supports the property's economic viability as assessed by a detailed discounted cash flow analysis or other similar financial analysis. In the absence of a discounted cash flow analysis or similar financial analysis that supports the economic viability of the Tshepong North mineral reserve, we would expect you to revise your annual filing to remove the Tshepong North mineral reserve and related disclosures. To the extent the elimination of the reserve materially impacts the depletion amounts recorded in your financial statements, please analyze these impacts and revise your financial disclosures as necessary.
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
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United States securities and exchange commission logo
April 18, 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 April 8, 2024
File No. 001-31545
Dear Boipelo Lekubo:
We have reviewed your April 8, 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 March 8,
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.In response to comment 1 we note you propose to include two separate cash flows
in the Tshepong North Technical Report Summary; one cash flow includes inferred
mineral resources and one cash flow is based solely on mineral reserves. In order to
satisfy the requirements of Item 1302(e)(6) of Regulation S-K, inferred resources cannot
be included in a pre-feasibility study or feasibility study cash flow. Therefore the cash
flow that includes inferred resources should be removed from the Tshepng North technical
report summary.
Item 1302(e)(5) of Regulation S-K requires a pre-feasibility study to include an economic
FirstName LastNameBoipelo Lekubo
Comapany NameHARMONY GOLD MINING CO LTD
April 18, 2024 Page 2
FirstName LastName
Boipelo Lekubo
HARMONY GOLD MINING CO LTD
April 18, 2024
Page 2
analysis that supports the property's economic viability as assessed by a detailed
discounted cash flow analysis or other similar financial analysis. In the absence of a
discounted cash flow analysis or similar financial analysis that supports the economic
viability of the Tshepong North mineral reserve, we would expect you to revise your
annual filing to remove the Tshepong North mineral reserve and related disclosures. To
the extent the elimination of the reserve materially impacts the depletion amounts
recorded in your financial statements, please analyze these impacts and revise your
financial disclosures as necessary.
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