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    HARMONY GOLD MINING COMPANY LIMITED

    First Floor 4 The High Street

    Suite No 1 Private Bag X1

    T +27 11 684 0140

    Melrose Arch Melrose North

    Melrose Arch 2076

    F +27 11 684 0188

    NYSE and NASDAQ

    2196 Johannesburg

    Johannesburg South Africa

    W  www.harmony.co.za

    trading symbol HMY

    JSE trading symbol HAR

18 May 2007

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

100 F STREET, NE

WASHINGTON, D.C.

2059-7410

BY EDGAR

    FOR ATTENTION:

    H. ROGER SCHWALL, ASSISTANT DIRECTOR

DIVISION OF CORPORATION FINANCE

Dear Sir,

REPLY TO REVIEW LETTER DATED 18 APRIL 2007

Reference is made to the Staff’s comment letter dated April 18, 2007 in respect of the Harmony
Gold Mining Company Limited (the “Company”) Form 20-F for the year ended June 30, 2006. Set forth
below in detail are the responses to the Staff’s comments, which have been provided in each case
following the text of the comment in the Staff letter:

Information on the Company, page 19

Year-on-year reconciliation of Harmony’s ore reserves, page 38

    1.

    We note your statement that you use “the South African code for the reporting of Exploration
Results, Mineral Resources and Ore Reserves (the SAMREC Code), which sets out internationally
recognized procedures and standards for reporting of mineral resources and ore reserves.” We
further note your disclosure that “In reporting of reserves, we have complied with Industry
Guide 7 of the United States Securities and Exchange Commissions. Please confirm, if true,
that the reserve quantities used to measure the financial results of your mining operations
are limited to proven and probable reserves, as defined by Industry Guide 7, or otherwise
advise.

    Response: The Company acknowledges the Staff’s comment and confirms that the reserve
quantities used to measure its financial results are limited to proven and probable reserves
as defined by Industry Guide 7.

    Directors:

    P T Motsepe* (Chairman), Z B Swanepoel (Chief Executive), F Abbott*, J A Chissano*#,
F T De Buck*,
 Dr D S Lushaba*, C Markus*, M Motloba*, N V Qangule, C M L Savage*

                 *Non-Executive; #Mozambican

    Secretary:

    M P van der Walt

Registration Number: 1950/038232/06

 2

Operating and Financial Review and Prospectus, page 133

Share –Based Compensation, page 147

    2.

    We note your statement that the “charge in fiscal 2006 relates to the amortization of the
fair value of the 2005, 2003 and 2001 options”; and that the “charge in fiscal 2005 relates to
the amortization of the fair value of the 2005, 2003 and 2001 option grants for Harmony.”
Please expand your disclosure to explain the nature of these charges.

    Response: On July 1, 2005, the Company adopted the fair value recognition provisions of FAS
123(R) using the modified retrospective approach. Under this method, share-based payment
expense for the year ended June 30, 2006 includes: (a) compensation cost for all share-based
payments granted prior to, but not yet vested as of July 1, 2005, based on the grant-date
fair value estimated in accordance with the original provisions of FAS 123, and (b)
compensation cost for all share-based payments granted subsequent to July 1, 2005, based on
the grant-date fair value estimated in accordance with the provisions of FAS 123(R). At the
same time, the results for prior periods were adjusted based on the amounts previously
recognized under FAS 123 for purposes of pro forma disclosures. In both cases, the Company
has recognized the share-based payment expense associated with options with graded-vesting
features over the requisite service period for each separately vesting tranche of the award
as though the award were, in substance, multiple awards.

    On a supplemental basis, the Company therefore wishes to advise the Staff that the “charge”,
or share-based payment expense, for both fiscal 2006 and 2005 represents the grant-date fair
value of the awards discussed on page F-50 of the Company’s FY 2006 20-F which are being
recognized over the employee’s requisite service period, which varies from three to five
years. The increase in the expense from fiscal 2005 to fiscal 2006 results primarily from the
share options granted on April 26, 2005, for which only two months of service were completed
in fiscal 2005, compared to a full year in fiscal 2006, and the depreciation of the Rand
against the US dollar, which increased the share-based charges in US dollar terms. The
Company will expand its Operating and Financial Review and Prospects in future filings to
clarify the nature of the charges as well as the reasons for any material movements/charges.

2 Accounting Policies, page F-7

(t) Revenue Recognition, page F-14

    3.

    We note you have revenues from silver and other by-products sales and that the sales are
credited to production costs as a by-product credit. Please expand your disclosure to include
that amount of such revenue for each period reported. Additionally, please expand your MD&A to
clearly indicate that you generate by-product revenue on certain of your operating units and
why you believe that presentation of these revenue streams as a by-product is appropriate.
Furthermore, include the trend analysis to identify the amount and types of by-product revenue
generated for each period presented and indicate whether or not you believe, based on your
estimate that presentation of these revenue streams as by-products will continue to be
appropriate in the future.

    Response: The Company wishes to advise the Staff on a supplemental basis that the revenues in
respect of “silver and other by-products”, which have been credited to production costs as a
by-product credit, amounted to US$1.3 million in fiscal 2006, US$4.0 million in fiscal 2005
and US$1.9 million in fiscal 2004. These sales have not historically been contemplated by the
Company’s mine plans and therefore are appropriately accounted for as by-products. This
treatment is supported by the fact that these amounts represent less than 0.3% of reported
sales in 2005 and 2004. The Company will consider the appropriateness of this policy in
future periods, based on the expected silver revenues from its Hidden Valley Project in Papua
New Guinea, which is still under development.

3

3 Accounting changes, page F-16

(b) Stripping costs incurred during the production phase of a mine, page F-17

    4.

    Please tell us what you mean by your disclosure that states “capitalization of
post-production stripping costs is appropriate only to the extent product inventory exists at
the end of a reporting period” and clarify your disclosure to explain how your accounting
policy complies with EITF 04-6.

    Response: Prior to July 1, 2005, at the Company’s Kalgold operations, deferred stripping
costs were charged to Production costs exclusive of depreciation and amortization as gold was
produced and sold using the units of production method based on estimated recoverable
quantities of proven and probable reserves, using a stripping ratio calculated as the ratio
of total tons to be moved to total proven and probable ore reserves, which resulted in the
recognition of the costs of waste removal activities over the life of the mine as gold was
produced. The application of the deferred stripping accounting method previously applied
resulted in the recognition of an asset (deferred stripping costs). Under the Company’s
revised policy, which complies with EITF 04-6, stripping costs incurred during the production
phase of a surface mine are treated as variable production costs and considered to be a
component of mineral inventory cost subject to the provisions of ARB 43. Post production
stripping costs are therefore expensed as incurred in the consolidated statements of
operations, except to the extent that those costs are considered to be a component of mineral
inventory on hand at the balance sheet date; in which case “capitalization of the
post-production costs would be appropriate” as a component of such mineral inventory. The
Company will clarify its disclosures in future filings.

    During the periods presented, the Company did not carry any material mineral inventories at
its Kalgold operations. All post-production stripping costs have therefore effectively been
expensed as incurred.

15 (Loss) /Earnings Per Share, page F-34

    5.

    We note your disclosure that the “inclusion of share options issued to employees as of June
30, 2006, as potential ordinary shares, would have an anti–dilutive effect on diluted loss per
share. Accordingly, such additional shares have not been taken into account in the
determination of diluted loss per share.” Please disclose the number of securities that could
potentially dilute basic earnings/loss per share in the future that were not included in the
computation of diluted earnings/loss per share because to do so would have anti-dilutive for
the period presented in accordance with paragraph 40(c) of FAS 128.

    Response: The weighted average number of ordinary shares that would have been included in the
computation of fully diluted loss per share amounted to 4,919,895 and 3,208,201 in fiscal
2006 and fiscal 2005, respectively. The Company will revise its future filings to incorporate
the disclosures required by paragraph 40(c) of FAS 128.

26 Long term Loans, page F-41

    6.

    We note that you issued an international unsecured fixed rate convertible bond totaling
R1,700 million in May 2004 and that “bonds are convertible at the option of bondholders at any
time on or after July 1, 2004 and up to and including May 15, 2009.” We further note that the
“number of ordinary shares to be issued at such a conversion shall be determined by dividing
the principal amount of each bond by the conversion price in effect on the relevant conversion
date.” Please tell us how you considered the guidance in FAS 150, FAS 133 and EITF 00-19 with
respect to your convertible bond and any associated embedded derivatives. You may wish to
refer to section II.B. within the outline entitled Current Accounting and Disclosure Issues in
the Division of Corporation Finance, located at
http://www.sec.gov/divisions/corpfin/cfacctdisclosureissues.pdf.

4

    Response: The Company acknowledges the Staff’s comment and wishes to advise the Staff that
it does not consider the convertible bond to be an instrument within the scope of FAS 150. In
particular, the Company notes that the instrument would not be considered to be a
“mandatorily redeemable financial instrument”, as a result of the conversion feature embedded
within the bonds which results in the bonds being “conditionally redeemable.” The initial
conversion price of the instruments was R121 per ordinary share, subject to certain standard
anti-dilution provisions, such as a stock split, spinoff or rights offering, that are
designed to maintain the value of the conversion option.

    With regard to the conversion feature, the Company has analyzed whether the embedded
conversion feature meets the paragraph 11(a) scope exception of FAS 133. In analyzing whether
the conversion feature meets the paragraph 11(a) scope exception, the Company considered the
guidance in paragraphs 7-32 of EITF 00-19 to determine whether the conversion feature should
be classified as a liability or within stockholder’s equity. In particular, the Company notes
that: (i) there are no provisions in the contract that could require net-cash settlement of
the conversion feature; (ii) the shares will not be registered in the United States and that
there are no further filing or registration requirements in South Africa that would preclude
the Company from controlling the delivery of the shares; (iii) the Company has sufficient
authorized and unissued shares available to settle the contract after considering all other
commitments that may require the issuance of stock during the maximum period the derivative
contract could be outstanding; and (iv) the number of shares to be delivered is effectively
capped at the initial conversion price as defined by the terms of the bond, as all
adjustments to the conversion price are either limited to events within the Company’s control
or contain an explicit cap on the conversion price. All other criterion not specified above,
but included in EITF 00-19 paragraph 7-32 have also been met.

    The Company has therefore determined the classification of the conversion feature to be
equity under EITF 00-19 and, since the conversion feature is indexed solely to the Company’s
own stock (as defined in EITF 01-6), the requirements in FAS 133 paragraph 11(a) have been
met. As such, the embedded conversion feature has not been bifurcated from the host contract.
Instead, the entire convertible instrument has been accounted for in accordance with APB 14.

    The Company will revise its future filings to expand the key disclosures surrounding the
convertible bonds, including the initial conversion price, in accordance with FAS 129.

Cash (Utilized) / Generated by Operations, page F-54

    7.

    We note that in providing the reconciliation to net cash flows from operating activities you
begin with loss before taxation, minority interest and effect of change in accounting
principal rather than net income/loss. Please revise your presentation to reconcile net
income/loss to net cash flow from operating activities, as contemplated by paragraph 28 of FAS
95.

    Response: The Company acknowledges the Staff’s comment and will revise its future
reconciliations of cash flows from operating activities to begin with net income/loss for all
periods presented, as contemplated by FAS 95. The Company notes that the change will not have
any impact on the cash flows from operations as previously reported.

Geographical and Segment Information, page F-56

    8.

    Please tell us how you have complied with the reconciliation requirement for segment
revenues, reported profit or loss, assets and other significant items to the corresponding
enterprise amounts in accordance with paragraph 25(c) of FAS 131.

5

    Response: The Company acknowledges the Staff’s comment and wishes to advise the Staff that on
pages F-56, F-59 and F-62 of its 2006 Annual Report on Form 20-F, it has
reconciled the segment data (segment revenue, production costs, total assets and total
liabilities) to its consolidated financial statements, with an aggregate reconciling
adjustment. The components of the total reconciling adjustment are discussed in narrative
format on pages F-63 to F-64. The Company has the information available as part of its U.S.
GAAP reconciliation working papers to support the components of each reconciling adjustment
and proposes to provide quantitative disclosure of the reconciling adjustments, on a
disaggregated basis, in future filings with the SEC.

Exhibits 4.20 and 4.21

    9.

    We note that your certification pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 is
worded such that it does not precisely match the language as set forth in the Act. Refer to
Instruction 12 to Item 19 of Form 20-F for the exact text of the required Section 302
certifications, and amend your exhibits as appropriate. In this regard and without
limitation, there is no provision for your certifying officer to identify the position held
with the Company in the first line of the certification. Please refer to FAQ 11 within the
Division of Corporation Finance: Sarbanes- Oxley Act of 2002 – Frequently Asked Questions,
located at http://www.sec.gov/divisions/corpfin/faqs/soxact2002.htm and amend your exhibits as
appropriate.

    Response: The Company acknowledges the Staff’s comment and will amend the
exhibits in its future filing.

Engineering Comments

General

    10.

    We note that your website and some press releases refer to or use the terms “measured”,
“indicated”, and “inferred”, resources. If you continue t