SEC Company Response from HARMONY GOLD MINING CO LTD (HMY, HGMCF) (CIK 0001023514) (HMY) — Nov 1, 2011
HARMONY GOLD MINING CO LTD (HMY, HGMCF) (CIK 0001023514)
Date: Nov. 1, 2011 · CIK: 0001023514 · Accession: 0001193125-11-290255
AI Filing Summary & Sentiment
Referenced dates: September 28, 2011
Letter
UNITED STATES SECURITIES DIVISION OF CORPORATION FINANCE Harmony Gold Mining Company Limited Form 20-F for Fiscal Year Ended June 30, 2010 Filed October 25, 2010 Comment Letter dated September 28, 2011
Dear Sirs,
We are writing in response to your September 28, 2011 letter to set forth our views with regard to the two points noted in that letter.
We note your comments regarding the SRK CPR in relation to the Poplar and Rolspruit projects and respond as follows:
In relation to the SRK statement in section 21.2.3 that there is “insufficient back up for the calculations done to estimate the Mineral Resources”:
•
section 21.2.3 does go on to state that that “the information supplied appears to be appropriate and support the reported Mineral Resources”
Thus, we believe that this section does not state that the reported Mineral Resources are not adequately supported. On the contrary, the portion of that section that we refer to states that the reported Mineral Resources are supported by the information supplied.
In relation to the classification of Indicated at Poplar being optimistic when compared to surrounding projects:
•
SRK adjusted the dilution factors as detailed in section 19.3.2 of the report (and specifically table 19.13 for Poplar, and also table 19.11 for Rolspruit).
Directors: PT Motsepe* (Chairman), GP Briggs (Chief Executive), HO Meyer (Financial Director), HE Mashego (Executive Director), F Abbott* JA Chissano*#, FFT De Buck*, KV Dicks*, Dr DS Lushaba*, CE Markus*, MJ Motloba*, M Msimang*, D Noko*, CML Savage*, J Wetton*, AJ Wilkens*
*Non-Executive; #Mozambican
Secretary: iThemba Governance and Statutory Solutions (Pty) Ltd
Registration Number: 1950/038232/06
•
The adjusted resource to reserve estimate was then used to populate the SRK techno-economic model.
•
The effect of the adjusted dilution factors can be seen in the table below and compares the Feb 2010 reserve estimate shown in table 19.12, with the adjusted reserve used in the SRK techno economic model.
•
The resultant NPV’s and IRR’s are tabulated in table 25.39 of the SRK report and show both projects to be robust, thereby allowing Harmony to declare the adjusted SRK resources and reserves.
•
The SRK techno economic model reserve figures were used in the June 2010 reserve declaration.
•
Hence SRK’s adjusted reserves were declared.
Poplar
Classification
Mt
Grade g/t
Content Au Moz
Feb 2010
Probable
13.50
7.45
3.23
July 2010
Probable
16.1
5.99
3.10
The figures for Rolspruit are as follows:
Rolspruit
Classification
Mt
Grade g/t
Content Au Moz
Feb 2010
Probable
24.45
8.71
6.84
July 2010
Probable
26.2
8.08
6.79
Thus, we believe the figures reported are appropriate and are not optimistic when compared to surrounding projects.
If you should have any further questions, please let us know.
Yours faithfully,
/s/ Hannes Meyer
Hannes Meyer
Chief Financial Officer
Date: November 1, 2011
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CORRESP 1 filename1.htm Correspondence HARMONY GOLD MINING COMPANY LIMITED Randfontein Office Park Cnr Main Reef Road and Ward Avenue, Randfontein 1759 PO Box 2, Randfontein, 1760 Johannesburg South Africa T +27 11 411 2000 F +27 11 411 W www.harmony.co.za NYSE trading symbol HMY JSE trading symbol HAR UNITED STATES SECURITIES AND EXCHANGE COMMISSION DIVISION OF CORPORATION FINANCE 100 F STREET, NE WASHINGTON, D.C. 20549 November 1, 2011 FOR ATTENTION: BRAD SKINNER SENIOR ASSISTANT CHIEF ACCOUNTANT CC: JOHN COLEMAN MINING ENGINEER MARK WOJCIECHOWSKI AND JOHN CANNARELLA STAFF ACCOUNTANTS RE: Harmony Gold Mining Company Limited Form 20-F for Fiscal Year Ended June 30, 2010 Filed October 25, 2010 Comment Letter dated September 28, 2011 Dear Sirs, We are writing in response to your September 28, 2011 letter to set forth our views with regard to the two points noted in that letter. We note your comments regarding the SRK CPR in relation to the Poplar and Rolspruit projects and respond as follows: In relation to the SRK statement in section 21.2.3 that there is “insufficient back up for the calculations done to estimate the Mineral Resources”: • section 21.2.3 does go on to state that that “the information supplied appears to be appropriate and support the reported Mineral Resources” Thus, we believe that this section does not state that the reported Mineral Resources are not adequately supported. On the contrary, the portion of that section that we refer to states that the reported Mineral Resources are supported by the information supplied. In relation to the classification of Indicated at Poplar being optimistic when compared to surrounding projects: • SRK adjusted the dilution factors as detailed in section 19.3.2 of the report (and specifically table 19.13 for Poplar, and also table 19.11 for Rolspruit). Directors: PT Motsepe* (Chairman), GP Briggs (Chief Executive), HO Meyer (Financial Director), HE Mashego (Executive Director), F Abbott* JA Chissano*#, FFT De Buck*, KV Dicks*, Dr DS Lushaba*, CE Markus*, MJ Motloba*, M Msimang*, D Noko*, CML Savage*, J Wetton*, AJ Wilkens* *Non-Executive; #Mozambican Secretary: iThemba Governance and Statutory Solutions (Pty) Ltd Registration Number: 1950/038232/06 • The adjusted resource to reserve estimate was then used to populate the SRK techno-economic model. • The effect of the adjusted dilution factors can be seen in the table below and compares the Feb 2010 reserve estimate shown in table 19.12, with the adjusted reserve used in the SRK techno economic model. • The resultant NPV’s and IRR’s are tabulated in table 25.39 of the SRK report and show both projects to be robust, thereby allowing Harmony to declare the adjusted SRK resources and reserves. • The SRK techno economic model reserve figures were used in the June 2010 reserve declaration. • Hence SRK’s adjusted reserves were declared. Poplar Classification Mt Grade g/t Content Au Moz Feb 2010 Probable 13.50 7.45 3.23 July 2010 Probable 16.1 5.99 3.10 The figures for Rolspruit are as follows: Rolspruit Classification Mt Grade g/t Content Au Moz Feb 2010 Probable 24.45 8.71 6.84 July 2010 Probable 26.2 8.08 6.79 Thus, we believe the figures reported are appropriate and are not optimistic when compared to surrounding projects. If you should have any further questions, please let us know. Yours faithfully, /s/ Hannes Meyer Hannes Meyer Chief Financial Officer Date: November 1, 2011