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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

29 June 2007

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

100 F STREET, NE

WASHINGTON, D.C.

2059-7410

BY EDGAR

FOR ATTENTION: JILL DAVIS, BRANCH CHIEF

Dear Sir,

REPLY TO REVIEW LETTER DATED 14 JUNE 2007

Reference is made to the Staff’s comment letter dated June 14, 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:

Form 20- F for Fiscal Year Ended June 30, 2006

2 Accounting Policies, page F-7

(m) Property, Plant and Equipment, page F-11

Mining assets

    1.

    Please tell us and disclose your accounting policy for stripping costs when multiple pits
exists with in a mining complex that share common infrastructure and processing equipment and
a common ore body. Specifically, address your accounting for stripping costs associated with
the initial overburden removal of newly created pits that are with in close proximity or
adjacent to producing pits.

    Response: The Company wishes to advise the Staff, consistent with its disclosures in its 2006
Annual Report on Form 20-F, that during fiscal 2006, only approximately 4.9% and 3.7% of its
total gold production came from its surface operations in South Africa and Australia,
respectively. Approximately 3% came of the Company’s total gold production came from the
Company’s Kalgold single open pit gold mine near Mafikeng in the North West Province of South
Africa. The Company’s remaining surface operations in South Africa (representing
approximately 1.9% of its total gold production) include the recovery of gold from areas
previously involved in mining and processing, such as metallurgical plants, waste rock dumps
and tailings dams (slimes and sand). The Company’s surface operations in Australia
(representing only 3.7% of the Company’s total gold production) have an average life-of-mine
of less than one year.

    The issue of accounting for stripping costs associated with the initial overburden removal of
newly created pits that are within close proximity or adjacent to producing

 2

    pits has therefore only been applicable to the Company in certain limited circumstances in
Australia, which does not materially impact the Company’s financial statements due to the
short life-of-mine. However, in determining whether those costs would be capitalized as part
of mine development costs, or expensed as part of stripping costs incurred during the
production phase of a mine, the Company would perform an analysis to determine whether the
newly created pit would constitute a “mine” in accordance with the response to the Staff’s
second comment below. If the new pit is considered to be a separate “mine”, the costs would
be capitalized as part of mine development costs prior to the extraction of more than a de
minimis amount of saleable material from the new pit. Stripping costs incurred after the
extraction of more than a de minimis amount of saleable material will be considered to be a
variable production cost. If the new pit is not considered to be a separate “mine”, all
stripping costs would be considered to be stripping costs incurred during the production
phase of a mine in accordance with EITF 04-6.

    2.

    We note from your disclosure on page F-17 that you adopted EITF 04-6 on July 1, 2005. Please
tell us how you define a “mine” for the purpose of determining the commencement of the
production stage and also for the purpose of accounting for stripping costs.

    Response: The Company acknowledges the Staff’s comment and wishes to advise the Staff on a
supplemental basis that, for its surface gold mining operations, it generally considers
workings of separate geological structures/mineral deposits to be separate “mines” for the
purpose of determining the commencement of the production stage and also for the purpose of
accounting for stripping costs. To determine whether separate workings of a common geological
structure/mineral deposit are, in effect, related to a new “mine”, the Company will generally
consider the following factors:

    •

    Whether separate and distinct areas of mining operations are contemplated by the mine
development plans;

    •

    Whether the expenditures most appropriately could be characterized as being related
to the enlargement of an existing mining operation, or the commencement of a new area of
operations separate and distinct from the Company’s existing surface mines;

    •

    The extent to which expenditures for tangible property (such as new ore haul roads
and the installation of new conveyor systems) will be required as part of the
development; and

    •

    Whether the expenditures are required due to an obstacle present in the existing ore
body such as a fissure or other geological abnormality.

    The Company acknowledges that the analysis as to whether separate workings of a common
geological structure/mineral deposit are, in effect, related to a new “mine”, requires
judgement and will consider expanding its accounting policies and critical accounting
policies in future filings to the extent that these judgements also represent material
judgements. However, for the periods presented in the Company’s 2006 Annual Report on Form
20-F, the Company does not consider this to be a material judgement, due to the limited
applicability in those years.

    3.

    Please tell us and disclose your accounting policy for costs incurred associated with
upgrading or converting measured, indicated and inferred resources to probable reserves
including drilling and analysis costs at locations that are either in production or
development stage.

    Response: The Company wishes to advise the Staff that costs incurred associated with
upgrading indicated and inferred resources or converting measured and indicated resources to
proven and probable reserves, including drilling and analysis costs at locations that are
either in production or development stage, are expensed as incurred in accordance with the
Company’s accounting policy relating to exploration costs, as described on page F-11 of its
2006 Annual Report on Form 20-F. The Company will clarify its policy in future filings.

3

    4.

    In addition, please clarify your accounting for drilling and study costs incurred beyond the
boundaries of your inferred resources at properties that are either in the production or
development stage.

    Response: The Company wishes to advise the Staff that drilling and study costs incurred
beyond the boundaries of our inferred resources at properties that are either in the
production or development stage, and prior to the establishment of a final (bankable)
feasibility study are expensed as incurred in accordance with the Company’s accounting policy
relating to exploration costs, as described on page F-11 of its 2006 Annual Report on Form
20-F.

38 Geographical and Segment Information, F-56

    5.

    We note from your response to prior comment number eight that you have “reconciled the
segment data (segment revenue, production costs, total assets and total liabilities) to [your]
consolidated financial statements, with an aggregate reconciling adjustment.” We further note
your proposal to provide quantitative disclosure of the reconciling adjustments, on a
disaggregated basis, in the future filings. Please tell us how your current and/ or future
segment disclosures complies with paragraph 32(b) of FAS 131, which also requires a
reconciliation of the total of the reportable segments’ measures of profit or loss to the
consolidated income before income taxes, extraordinary items, discontinued operations, and the
cumulative effect of changes in accounting principles.

    Response: The Company acknowledges the Staff’s comment and wishes to advise the Staff on a
supplemental basis of the following breakdowns of the reconciling items for Revenue,
Production costs, Total assets and Total liabilities. The Company will revise its future
filings to also incorporate these quantitative disclosures in addition to the discussion of
differences already included in its geographical and segment information. The Company will
also expand its disclosures to clarify that cash operating profit / (loss) (representing
revenue less production costs which have both been separately reconciled), represents its
reportable segments’ measure of profit or loss, which can then be reconciled to consolidated
income before income taxes, extraordinary items, discontinued operations, and the cumulative
effect of changes in accounting principles as set out below.

    2006

    2005

    2004

    $’000

    $’000

    $’000

    Revenue

    Reversal of proportionate consolidation (a)

    —

    —

    (54,097
    )

    Other items

    —

    —

    18,123

    —

    —

    (35,974
    )

    2006

    2005

    2004

    $’000

    $’000

    $’000

    Production costs

    Reversal of proportionate consolidation (a).

    2,967

    —

    (35,963
    )

    Depreciation and amortization expense
(excluding depreciation on non-mining
assets) (b)

    159,433

    145,325

    136,729

    Share-based compensation (b)

    17,055

    15,618

    9,446

    Corporate costs and decrease in
rehabilitation costs (b)

    18,735

    16,155

    (3,646
    )

    Other items

    2,757

    (3,403
    )

    22,415

    200,947

    173,695

    128,981

4

    2006

    2005

    2004

    $’000

    $’000

    $’000

    Reconciliation of cash operating profit to
consolidated loss before income taxes, equity
income of joint venture, equity (loss)/income
of associated companies, impairment of
investment in associate and the cumulative
effect of change in accounting principle:

    Total segment revenue

    1,263,333

    1,265,200

    1,276,313

    Total segment production costs

    (1,034,052
    )

    (1,124,742
    )

    (1,104,790
    )

    Cash operating profit

    229,281

    140,458

    171,523

    Reversal of proportionate consolidation (a)

    (2,967
    )

    —

    (18,134
    )

    Depreciation and amortization expense
(excluding depreciation on non-mining assets)
(b)

    (159,433
    )

    (145,325
    )

    (136,729
    )

    Share-based compensation (b)

    (17,055
    )

    (15,618
    )

    (9,446
    )

    Corporate costs and decrease in rehabilitation
costs (b)

    (18,735
    )

    (16,155
    )

    3,646

    Other items

    (2,757
    )

    3,403

    (4,292
    )

    28,334

    (33,237
    )

    6,568

    Depreciation and amortization expense on
non-mining assets

    (6,687
    )

    (6,642
    )

    (3,100
    )

    Impairment of assets

    (15,951
    )

    (243,124
    )

    (3,145
    )

    Employment termination and restructuring costs

    12,289

    (73,215
    )

    (31,668
    )

    Care and maintenance cost of restructured shafts

    (27,387
    )

    (29,975
    )

    —

    Exploration expenditure

    (16,803
    )

    (11,676
    )

    (15,810
    )

    Marketing and new business expenditure

    (9,171
    )

    (15,310
    )

    (12,533
    )

    Post retirement benefits expense

    (1,175
    )

    (9,137
    )

    —

    Operating loss

    (36,551
    )

    (422,316
    )

    (59,688
    )

    Total other (expenses)/income

    (107,577
    )

    (219,044
    )

    16,165

    Loss before income taxes, equity income of
joint venture, equity (loss)/income of
associated companies, impairment of investment
in associate and the cumulative effect of
change in accounting principle

    (144,128
    )

    (641,360
    )

    (43,523
    )

    2006

    2005

    2004

    $’000

    $’000

    $’000

    Total assets

    Reversal of proportionate consolidation (a)

    (1,155
    )

    —

    —

    Exploration costs (c)

    (10,577
    )

    (11,367
    )

    (12,224
    )

    Business combinations — goodwill (d)

    14,605

    15,696

    16,804

    Business combinations — acquisition date (e)

    (284,274
    )

    (305,509
    )

    (327,070
    )

    Business combinations — purchase price (f)

    78,544

    85,906

    93,925

    Impairment of assets (g)

    (76,421
    )

    (32,022
    )

    (40,777
    )

    Provision for environmental rehabilitation (h)

    10,881

    11,330

    14,070

    Deferred taxation (i)

    (133,578
    )

    (133,076
    )

    71,132

    Borrowings (j)

    3,605

    5,733

    8,096

    Transfer of ARM shares to ARM Trust (k)

    61,358

    18,858

    —

    Other items

    32,381

    9,386

    (24,214
    )

    (304,632
    )

    (335,065
    )

    (200,257
    )

    2006

    2005

    2004

    $’000

    $’000

    $’000

    Total liabilities

    Reversal of proportionate consolidation (a)

    (1,154
    )

    —

    —

    Business combinations — purchase price (f)

    56,033

    61,556

    67,479

    Impairment of assets (g)

    (19,499
    )

    (10,977
    )

    (11,435
    )

    Provision for environmental rehabilitation (h)

    (5,940
    )

    (2,313
    )

    2,110

    Deferred taxation (i)

    (133,578
    )

    (133,076
    )

    71,132

    Borrowings (j)

    28,294

    40,432

    53,863

    Transfer of ARM shares to ARM Trust (k)

    61,358

    18,858

    —

    Other items

    22,918

    28,244

    1,651

    8,432

    2,724

    184,800

5

a) Reversal of proportionate consolidation

For management reporting purposes, the Company accounts for its investments in joint ventures using
the proportional consolidation method. Under U.S. GAAP, the equity method of accounting is applied
in accounting for all incorporated joint ventures.

b) Difference in calculation of production costs

Production costs for management reporting purposes excludes depreciation and amortization of mining
assets, share-based compensation, certain corporate costs and decrease in rehabilitation costs.
Under U.S. GAAP, all these items would be included in production costs. The items appearing in the
reconciliation of production costs in the table above includes the impact of the other differences
between IFRS and U.S. GAAP, such as those relating to exploration costs, business combinations and
provision for environmental rehabilitation, discussed further below.

c) Exploration costs

For management reporting purposes, certain exploration costs are capitalized. U.S. GAAP does not
permit the capitalization of exploration and evaluation expenditure prior to the establishment of a
bankable feasibility study.

d) Business combinations — goodwill

For management reporting purposes, prior to 2004, goodwill was amortized using the straight-line
method over the estimated life of the underlying asset. Under U.S. GAAP, goodwill is not subject to
amortization. Instead, the Company evaluates, on at least an annual basis, the carrying amount of
goodwill to determine whether current events and circumstances indicate that such carrying amount
may no longer be recoverable. From July 1, 2004, this treatment is in line with management’s
reporting.

e) Business combinations — acquisition date

For management reporting purposes, the Free Gold Company results have been included from the date
upon which the Company assumed joint operational control of the assets together with the seller.
Under U.S. GAAP, the Company accounts for its interest in the Free Gold Company from the date that
all the conditions precedent to the transaction were met, and the assets were n