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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 and NASDAQ

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

FOR ATTENTION:

TIA L. JENKINS

SENIOR ASSISTANT CHIEF ACCOUNTANT

CC:

SUYING LI

BRIAN BHANDARI

RE:

Harmony Gold Mining Company Limited

Form 20-F for Fiscal Year Ended June 30, 2012

Filed October 29, 2012

Comment Letter dated April 23, 2013

 May 17, 2013

 Dear Sirs,

 Reference is made to the Staff’s comment letter dated April 23, 2013
in respect of the Harmony Gold Mining Company Limited (the “Company”) Form 20-F for the year ended June 30, 2012 and the Company’s response letter dated April 5, 2013. Set forth below in detail is the response to the
Staff’s comment, which follows the text of the comment in the Staff letter:

 Form 20-F for Fiscal Year Ended June 30, 2012

 Financial Statements

 Notes to the Consolidated Financial Statements

 2 Accounting policies

 2.5 (vi) Depreciation and amortization of mining assets, page F-12

1.
We reviewed your response to prior comments 3 and 5. Please provide the following information related to your Doornkop South Reef and Masimong mines.

•

 Please supplement for us your reconciliation of proven and probable reserves for the three years ended June 30, 2012 with a rollforward
for each year showing reserves consumed and those converted from resources.

Directors:

PT Motsepe* (Chairman), MJ Motloba* (Deputy Chairman), GP Briggs (Chief Executive), F Abbott (Financial Director), HE Mashego (Executive Director), JA Chissano*#, FFT De Buck*, KV Dicks*, Dr DS Lushaba*, CE Markus*, M Msimang*, J
Wetton*, AJ Wilkens*, K Nondumo*, V Pillay*

*Non-Executive; #Mozambican

Secretary:

Riana Bisschoff

Registration Number:

1950/038232/06

•

 Please provide PDF copies of the maps for your Doornkop South Reef mine as of June 30, 2011 and June 30, 2010 along with the
reserve/resource information and the mine plan panels or stop outline similar to your Maps 1(a) and 1(b) as provided previously.

•

 Please provide PDF copies of the maps for your Masimong mine with the superimposed life of mine panels or stop outline and the
reserve/resource information as the end of each of the last three fiscal years in the period ended June 30, 2012 as included in the Map 2(a), but of the same general area and scale.

Response: The Company acknowledges the Staff’s comment on the reconciliation of the proven and probable reserves and has included the
information below. The PDF copies of the maps requested have been included at the end of this response letter.

 Reconciliation of proven
and probable reserves for the three fiscal years ended June 30, 2012

 Figures are in tonnes (‘000)

Doornkop South Reef

Masimong

 Opening balance of proven and probable reserves – June 30, 2009

1 292

5 862

 Consumed

(205
)

(567
)

 Converted from resources

1 049

2 019

 Closing balance of proven and probable reserves – June 30, 2010

2 136

7 314

 Consumed

(82
)

(625
)

 Converted from resources

1 169

(119
)

 Closing balance of proven and probable reserves – June 30, 2011

3 223

6 570

 Consumed

(435
)

(544
)

 Converted from resources

2 123

832

 Closing balance of proven and probable reserves – June 30, 2012

4 911

6 858

2.
We reviewed your response to our prior comment 3, noting your depreciable base includes both capitalized costs as well as future development costs necessary to
access reserves and inferred resources at the Doornkop South Reef and Masimong mines. Considering access of such reserves and resources occur over time, tell us how your depreciation calculation allocates the depreciable base between the portion
currently in use versus the portion not in use. For guidance, refer to paragraphs 43 through 45 of IAS 16.

 Response:
The Company acknowledges the Staff’s comment on our depreciation calculation and the allocation of future development costs to the depreciable base. In determining the depreciation to be expensed on the Doornkop and Masimong mines, the mine is
separated into its significant parts or components and each of these parts or components, excluding the main shaft infrastructure, are depreciated over the relevant portion of the reserve base using the unit of production method.

The main shaft infrastructure component is depreciated over the total reserve/resource base included in the life-of-mine plan using the unit of
production method. The depreciable base is increased by adding the expected future development costs. The depreciation calculation allocates the larger depreciable base proportionately over the life-of-mine and therefore results in a depreciation
charge that reflects the pattern of consumption over the life-of-mine.

 2

 The Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the
filings it makes with the Commission. It understands that staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing and that the Company may not assert
staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Yours faithfully

 /s/ F Abbott

F Abbott

Financial Director

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