SEC Company Response from HARMONY GOLD MINING CO LTD (HMY, HGMCF) (CIK 0001023514) (HMY) — Feb 14, 2017
HARMONY GOLD MINING CO LTD (HMY, HGMCF) (CIK 0001023514)
Date: Feb. 14, 2017 · CIK: 0001023514 · Accession: 0001654954-17-001025
AI Filing Summary & Sentiment
File numbers found in text: 001-31545
Referenced dates: January 31, 2017
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance United States of America Harmony Gold Mining Company Limited Form 20-F for Fiscal Year Ended June 30, 2016 Filed October 26, 2016 File No. 001-31545
Dear Mr. Reynolds:
Harmony Gold Mining Company Limited (the “Company”) hereby responds to the comments of the staff (the “Staff”) of the United States Securities and Exchange Commission contained in your letter dated January 31, 2017 (the “Comment Letter”) regarding the Company’s Annual Report on Form 20-F for the fiscal year ended June 30, 2016. For the convenience of the Staff, we have set forth below the comments contained in the Comment Letter followed by the Company’s response to each comment.
Form 20-F for the Fiscal Year Ended June 30, 2016
Exhibit 99.33
General
Comment No. 1
We note your disclosure of mineral resources on pages 6, 111, 113, and 114 of your integrated annual report. Only proven and probable reserves may be disclosed in filings with the United States Securities and Exchange Commission. Please remove these mineral resources.
Directors:
PT Motsepe* (Chairman), JM Motloba* (Deputy Chairman), PW Steenkamp (Chief Executive), F Abbott (Financial Director), HE Mashego (Executive Director), JA Chissano*#, FFT De Buck*, KV Dicks*, Dr DSS Lushaba*, CE Markus*, M Msimang*, JL Wetton*, AJ Wilkens*, KT Nondumo*, VP Pillay*
*Non-Executive; #Mozambican
Secretary:
Riana Bisschoff
Registration Number:
1950/038232/06
Company Response to Comment No. 1
The Company respectfully acknowledges the Staff’s comment related to mineral resources on pages 6, 111, 113 and 114 of its integrated annual report and confirms that it will revise its disclosure in future filings accordingly.
Comment No. 2
Please tell us if the financial metrics related to your Golpu feasibility study on pages 115, 116, and 119 of your annual report are before tax numbers or after tax numbers and clarify the disclosure.
Company Response to Comment No. 2
The Company respectfully acknowledges the Staff’s comment and clarifies that the financial metrics related to the Company’s Golpu feasibility study on pages 115, 116, and 119 of its integrated annual report are presented on an after tax basis. The Company respectfully confirms that it will revise its disclosure in future filings accordingly.
Please feel free to contact me by telephone at [011 27 11 411 2231] or by email at frank.abbott@Harmony.co.za should you have any questions or comments. You may also contact [John M. Basnage of Hogan Lovells US LLP by telephone at 011 44 20 7296 2766 or by email at john.basnage@hoganlovells.com] [Riana Bisschoff by telephone at 011 27 11 411 6020 or by email at riana.bisschoff@harmony.co.za].
Sincerely,
/s/ Frank
Abbott
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HARMONY GOLD MINING
COMPANY LIMITED
Randfontein Office Park
Cnr Main Reef Road and
Ward
Avenue, Randfontein, 1759
P O Box 2, Randfontein, 1760
Johannesburg, South
Africa
T
+27 11 411 2000
F
+27 11 692 3879
W
www.harmony.co.za
NYSE trading symbol HMY
JSE trading symbol
HAR
VIA EDGAR
United States
Securities and Exchange Commission
Division of
Corporation Finance
100 F Street,
NE
Washington,
DC 20549
United States of
America
Attn:
John Reynolds
Office Director
Offices of Beverages, Apparel
and Mining
Re:
Harmony
Gold Mining Company Limited
Form 20-F
for Fiscal Year Ended June 30, 2016
Filed
October 26, 2016
File No.
001-31545
Dear Mr.
Reynolds:
Harmony Gold
Mining Company Limited (the “Company”) hereby responds to the
comments of the staff (the “Staff”) of the United States
Securities and Exchange Commission contained in your letter dated
January 31, 2017 (the “Comment Letter”) regarding the
Company’s Annual Report on Form 20-F for the fiscal year
ended June 30, 2016. For the convenience of the Staff, we have set
forth below the comments contained in the Comment Letter followed
by the Company’s response to each comment.
Form 20-F for the Fiscal Year Ended June 30, 2016
Exhibit 99.33
General
Comment No. 1
We note your disclosure of mineral resources on pages 6, 111, 113,
and 114 of your integrated annual report. Only proven and probable
reserves may be disclosed in filings with the United States
Securities and Exchange Commission. Please remove these mineral
resources.
Directors:
PT Motsepe* (Chairman), JM
Motloba* (Deputy Chairman), PW Steenkamp (Chief Executive), F
Abbott (Financial Director), HE Mashego (Executive Director), JA
Chissano*#, FFT De Buck*, KV
Dicks*, Dr DSS Lushaba*, CE Markus*, M Msimang*, JL Wetton*, AJ
Wilkens*, KT Nondumo*, VP Pillay*
*Non-Executive; #Mozambican
Secretary:
Riana Bisschoff
Registration
Number:
1950/038232/06
Company Response to Comment No. 1
The Company
respectfully acknowledges the Staff’s comment related to
mineral resources on pages 6, 111, 113 and 114 of its integrated
annual report and confirms that it will revise its disclosure in
future filings accordingly.
Comment No. 2
Please tell us if the financial metrics related to your Golpu
feasibility study on pages 115, 116, and 119 of your annual report
are before tax numbers or after tax numbers and clarify the
disclosure.
Company Response to Comment No. 2
The Company
respectfully acknowledges the Staff’s comment and clarifies
that the financial metrics related to the Company’s Golpu
feasibility study on pages 115, 116, and 119 of its integrated
annual report are presented on an after tax basis. The Company
respectfully confirms that it will revise its disclosure in future
filings accordingly.
Please feel free
to contact me by telephone at [011 27 11 411 2231] or by email
at frank.abbott@Harmony.co.za should you have any questions or
comments. You may also contact [John M. Basnage of Hogan Lovells US
LLP by telephone at 011 44 20 7296 2766 or by email at
john.basnage@hoganlovells.com] [Riana Bisschoff by telephone at 011
27 11 411 6020 or by email at
riana.bisschoff@harmony.co.za].
Sincerely,
/s/ Frank
Abbott
Frank
Abbott
Chief Financial
Officer
Financial
Director