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HARMONY GOLD MINING COMPANY LIMITED

Randfontein Office Park            P O Box 2, Randfontein, 1760    T +27 11 411 2000                  NYSE trading symbol HMY

Cnr Main Reef Road and Ward            Johannesburg, South Africa        F +27 11 692 3879                  JSE trading symbol HAR

Avenue, Randfontein, 1759                    W www.harmony.co.za

UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

DIVISION OF CORPORATION FINANCE

100 F STREET, NE

WASHINGTON, D.C.

20549

FOR ATTENTION:     STEVE LO

SHANNON BUSKIRK

JOHN COLEMAN

RE:             Harmony Gold Mining Company Limited

Form 20-F for Fiscal Year Ended June 30, 2023

Filed October 31, 2023

Comment Letter dated January 19, 2024

February 19, 2024

Ladies and Gentlemen,

Reference is made to the Staff’s comment letter dated January 19, 2024 in respect of the Harmony Gold Mining Company Limited (the "Company" or “Harmony”) Form 20-F for the year ended June 30, 2023. Set forth below is the response to the Staff’s comment, which follows the text of the comment in the Staff letter:

Form 20-F For the Fiscal Year Ended June 30, 2023

Item 16F. Change in Registrant's Certifying Accountant, page 182

1.Please revise to state whether you consulted your new independent principal accountants, Ernst & Young, Inc., during the two most recent fiscal years or any subsequent interim period and provide required disclosures pursuant to Item 16F(a)(2) of Form 20-F.

Response: The Company acknowledges the Staff’s comment regarding consultation with its incoming principal accountants, Ernst & Young, Inc. (“EY”). In considering the disclosure requirements of Item 16F(a)(2) in preparing our Form 20-F for the year ended June 30, 2023, the Company determined that EY was a new independent accountant and accordingly Harmony identified EY and indicated the date of EY’s engagement in our Form 20-F for the year ended June 30, 2023 pursuant to the requirement of Item 16F(a)(2). During the fiscal years ended June 30, 2023 and 2022 and the subsequent interim period through October 31, 2023, Harmony has not consulted with EY, either in writing or orally, regarding any of the matters described in Item 16F(a)(2)(i) or Item 16F(a)(2)(ii) of Form 20-F.

The Company interpreted the additional disclosure requirements pursuant to Item 16F(a)(2)(ii)(A) through (D) as conditional on occurrence of a matter described in item 16F(a)(2)(i) or Item 16F(a)(2)(ii) based on the conditional “if” language in Item 16(F)(a)(2). Given the absence of such matters, Harmony did not provide such additional disclosure; had there been any consultation in the fiscal periods mentioned, the fact would have been disclosed in the Form 20-F and the disclosures required by Item 16F(a)(2)(ii)(A)-(D) would have been provided by Harmony. However, in response to the Staff’s comment, we will provide disclosure regarding the absence of any of the matters described in item 16F(a)(2)(i) or Item 16F(a)(2)(ii) in our Form 20-F for the year ended June 30, 2024.

Directors:    PT Motsepe* (Chairman), KT Nondumo* (Deputy Chairman), M Msimang*, PW Steenkamp (Chief Executive), BP Lekubo (Financial Director),

    HE Mashego (Executive Director), JL Wetton*, VP Pillay*, GR Sibiya*, PL Turner*, B Nqwababa*, M Prinsloo*

        *Non-Executive

Secretary:             SS Mohatla

Registration Number:     1950/038232/06

Item 19. Exhibits

96.12 Technical Report Summary of the Mineral Resources and Mineral Reserves for Tshepong North, Free State Province, South Africa, page 189

2.We note that the gold recovered in your life of mine plan exceeds the gold content disclosed in your mineral reserve table. For example the gold recovered listed in Table 19.4 is 24,789 kg, which is greater than the gold content of 18,731 kg listed in Table 12-4. Please explain these differences. To the extent materials other than reserves have been included in your life of mine plan and cash flow analysis, please tell us the nature of these materials. Only mineral reserves should be included in the cash flow analysis of a preliminary feasibility study or feasibility study, in order to meet the requirements of Item 1302(e)(3) of Regulation S-K, and the definition of a mineral reserve under Item 1300 of Regulation S-K.

Response: The Company acknowledges the Staff’s comment regarding the Mineral Reserves for Tshepong North. The Company confirms that the difference between Table 19.4 Tshepong North Cash Flow and Table 12.4 Summary of Tshepong Mineral Reserve as at June 30, 2023 is the inclusion of Inferred Resources in the Economic Business Plan, also known as Life of Mine (“LoM”). The Company believes this to be appropriate for the reasons set out below.

Harmony has a long-established reporting process whereby Mineral Resources and Reserves are declared in accordance with the Subpart 1300 (17 CFR 229.1300) of Regulation S-K) and technical report summaries are disclosed within the requirements of Item 601(b)(96) (17 CFR 229.601(b)(96)) under Regulation S-K. The purpose is to provide open and transparent disclosure of all material, exploration activities, Mineral Resource and Mineral Reserve information to enable the investor to understand the operations which form part of Harmony’s activities.

Harmony has a consistent track record of converting Inferred Resources to Proven and Probable Reserves. Harmony Gold has extensively mined gold within the Witwatersrand Basin since the 1950s and is a well-established company which has grown its Mineral Resource and Reserve base through exploration and acquisitions. Harmony has demonstrated the ability to turn marginal mines into profitable entities and thereby extending the LoM for various mines within the Witwatersrand. The success is due to a well embedded understanding of the orebody supported by extensive brownfield and greenfield exploration strategies. Additional confidence in the existence and commercial viability of the gold bearing reefs is obtained from the fact that the Harmony operations have been mined over many years where continuations of the same gold bearing reefs are exploited.

Inferred Mineral Resource is that part of a Mineral Resource for which quantity and grade are estimated on the basis of limited geological information. In specific cases, Inferred Mineral Resources which are in close proximity to the Mineral Reserve blocks are included in the Life of Mine plan (LoM Plan) economic assessment however are not included in the Mineral Reserve due to their Mineral Resource classification. Should the Competent Person have confidence that the Inferred Mineral Resources will be converted into Reserves, then Inferred Resources are included in the LoM Plan economic assessment.

In the case of Tshepong North Operation, certain B-Reef Inferred Mineral Resources were included during the economic assessment of the June 2023 LoM Plan. For the past 15 years, the B-Reef has drawn attention for its economic viability with focus on improving confidence in the geological model, as well as adding and upgrading Mineral Resources to replace the mining depletion and is mined as a secondary reef. The Inferred Mineral Resources included in the LoM Plan are supported by limited drilling and underground sampling, however are within close proximity to the current Proved and Probable Reserves. The Company has identified that further geological confirmation drilling is required to improve and upgrade the Inferred Mineral Resources into Reserves. During the June 2023 Mineral Resource assessment, an exploration strategy was approved and comprised of an extensive drilling program to convert the Inferred Mineral Resources into Indicated Resources. Furthermore, as the current mining faces move towards the areas of Inferred Mineral Resources, additional stope sampling information becomes available, which pushes the estimation confidence halos into the Inferred Resource areas. The maps below (Map 1a, b and c) indicate the anticipated upgrade of the B-Reef Inferred Mineral Resource into Indicated Resources after the completion of the drilling program and the inclusion of additional underground sampling from the operation.

The Company has not performed any cash flow analysis of a preliminary feasibility study or feasibility study during the year ended June 30, 2023 for Tshepong North.

Page 2

Map 1(a): Tshepong North B-Reef Resource and Reserve indicating Exploration Targets as at June 30, 2023

Map 1(b): Tshepong North B-Reef Confidence Halos as at June 30, 2023

Map 1(c): Tshepong North B-Reef Confidence Halos Outlook as at 30 June 30, 2024

Page 3

3.Please tell us if capital costs and the extent to which closing costs have been included in the Tshepong North cash flow analysis. Additionally, please reconcile the difference between the Total Operating Cost line item in Table 19-4, and the Summary of Operating Cost Estimate for Tshepong North in Table 18-2.

Response: The Company acknowledges the Staff’s comment on the inclusion of capital and closing costs in the Tshepong North cash flow analysis. The Capital (including OCD) line was erroneously disclosed as zeros in Table 19-4. The Company will ensure that the error does not reoccur in future filings.

The corrected Table 19-4 is presented below:

Item Units LOM Total FY2024 FY2025 FY2026 FY2027 FY2028 FY2029 FY2030

Mining advance m2

 1,324,881 193,473 193,635 193,557 193,539 194,301 194,277 162,099

Total OCD m 27,733 5,964 5,368 5,915 5,727 3,118 1,312 329

Milled tons t '000 4,870 710 710 720 710 710 710 590

Yield g/t 5.802 4.67 4.73 4.95 4.84 4.93 4.80 4.88

Gold recovered kg 24,789 3,455 3,569 3,757 3,662 3,722 3,610 3,013

Revenue ZAR'000 20,451,163 2,850,775 2,944,673 3,099,147 3,021,299 3,070,752 2,978,389 2,486,130

Total operating costs ZAR'000 18,609,859 2,739,803 2,724,031 2,737,169 2,727,321 2,681,127 2,647,763 2,352,645

Capital (including OCD) ZAR'000 1,646,983 421,553 326,232 332,231 303,825 173,654 78,428 11,060

Royalty ZAR'000 185,886 14,254 14,723 15,496 15,106 41,173 48,522 36,612

Total costs (including capital and royalty) ZAR'000 20,442,728 3,175,609 3,064,987 3,084,896 3,046,252 2,895,953 2,774,713 2,400,317

Profit (after OCD and capital) ZAR'000 8,435 -324,834 -120,314 14,250 -24,954 174,799 203,676 85,813

NPV - (low discount rate - 9%) @9% -123,958

NPV - (medium discount rate - 12%) @12% -150,469

NPV - (high discount rate - 15%) @15% -171,116

The cash flow analysis does not include any closing costs. This is due to the fact that the South African mining regulations require funding to be set aside for future rehabilitation. Tshepong North’s rehabilitation liability is fully funded (i.e. there are sufficient investments and cash set aside to cover all estimated future costs) and therefore the closure costs have been excluded.

The information in Table 18-2 has not been correctly disclosed. For this reason, the total cost line per Table 18-2 and Table 19-4 will not reconcile.

The corrected Table 18-2 is presented below:

Operating Cost Element (ZAR'000) Total LOM (FY24 - FY30)

Mining 9,204,513

Services 1,313,124

Medical Hub / Station 409,515

Engineering 5,962,265

Plant 887,713

Total Direct Costs 17,777,130

Mine Overheads 832,729

Royalties 185,886

Ongoing Capex 1,268,339

Total Cost 20,064,084

As the disclosure forms part of the exhibit and not the annual financial statements, management has assessed the impact to be quantitatively and qualitatively immaterial to an investor’s decision. The Company will ensure that the error does not reoccur in future filings.

Page 4

Exhibit 99.1

Notes to the Group Financial Statements

15. Property, Plant and Equipment

Depreciation, page F-33

4.Your accounting policy appears to indicate you include inferred resources into the unit-of production calculation for determining the amount of depreciation of your mining assets, when you have confidence that such inferred resources will be converted into reserves. In order to enhance our understanding of your accounting policy, please address the following points:

•Tell us the percentage and amount of inferred resources that you include in the portion of mineralization expected to be classified as reserves;

•Provide us with your history of converting inferred resources into proven and probable reserves;

•Tell us the number of years of historical data that you have used to estimate your projected rates of converting inferred resources to proven and probable reserves;

•Explain to us whether or not and why historical trends are indicative of future conversion rates;

•If you have a consistent track record of converting inferred resources to proven and probable reserves, please explain the reasons for your success, given that the information you have about resources is significantly less than the information and supporting technical data that you have about proven and probable reserves; and

•Tell us to the extent which resources are currently accessible and the extent which additional capital improvements are required to convert and gain access to inferred resources.

Response: The Company acknowledges the Staff’s comment on the depreciation and amortization policy and our responses are set out below.

Harmony has an established history of converting Mineral Resources included in the LoM Plan into Mineral Reserves. During the Mineral Resource and Reserve assessment for the fiscal year ending June 2023 which was presented in the Company’s Form 20-F, the inclusion of Inferred Mineral Resources was undertaken at Tshepong North, Tshepong South, Target 1, Doornkop South Reef, Moab Khotsong and Mponeng in addition to Proven and Probable Reserves. This was for certain, but not all, Inferred Resources associated with these properties.

Tell us the percentage and amount of inferred resources that you include in the portion of mineralization expected to be classified as reserves

As at June 30, 2023, 22.569 million tonnes of Inferred Mineral Resources were included in the portion of mineralization expected to be converted into Mineral Reserves (see table below), this represents 1.81% of Harmony’s South Africa gold operations Mineral Reserves.

Page 5

Tell us the number of years of historical data that you have used to estimate your projected rates of converting inferred resources to proven and probable reserves

Historical data has not been used in the estimate for projected rates of converting inferred resources to proven and probable reserves. This is due to historical trends not being representative of future conversions, therefore other methods of prediction are used in the modeling.

Explain to us whether or not and why historical trends are indicative of future conversion rates

Historical trends are not indicative of future conversion rates as the conversion is based on exploration strategies that comprised a combination of extensive drilling, raise development and current mining, in order to gather sufficient geological and sampling data to allow the conversion. For Inferred Mineral Resources to be included in the LoM Plan, management must demonstrate that the Mineral Resource can be economically mined and is therefore commercially viable.

This consistent systematic method for inclusion of Inferred Mineral Resources in the LoM Plan takes management’s view of the gold price, exchange rates as well as cost inflation into account. The Board of Directors and management approach economic decisions affecting these operations based on the LoM Plans that include such Mineral Resources. The LoM Plan and the supporting Mineral Resources and Reserves are revised annually. The amount of Mineral Resources included in the depreciation calculation also changes annually. The relevant statistics for shafts with inferred resources for the past four years are indicated in the Appendix 1, Table 1. As at June 2021 the Mponeng tonnes were included following the Mponeng acquisition from AngloGold Ashanti. After J