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CORRESP
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November 3,
2023

Via EDGAR

United States Securities and Exchange
Commission

Division of Corporation Finance

Office of Energy & Transportation

100 F Street, N.E.

Washington, D.C. 20549

Attention: John Coleman and Karl Hiller

    Re:
    Sibanye Stillwater Limited

    Form 20-F for the Fiscal Year Ended December 31, 2022

    Filed April 24, 2023

    File No. 333-234096

Dear Messrs. Coleman and Hiller:

I refer to your
letter dated October 5, 2023 (the “October Comment Letter”), setting forth comments of the Staff of the Division
of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) in connection
with our September 28, 2023 response letter (the “September Response Letter”) to the Staff’s comment
letter dated August 23, 2023 relating to the annual report on Form 20-F for the fiscal year ended December 31, 2022 (the
 “2022 Form 20-F”) of Sibanye Stillwater Limited (the “Company” and, together with its subsidiaries,
 “Sibanye-Stillwater” or the “Group”) (File Number 333-234096).

Sibanye-Stillwater’s
responses to the Staff’s October Comment Letter are set forth below. To facilitate the Staff’s review, we have included
in this letter the captions and numbered comments from the October Comment Letter in italicized text and have provided our responses
immediately following each numbered comment. Capitalized terms that are not defined in this response letter have the meaning given to
them in the September Response Letter.

Form 20-F for the Fiscal
Year Ended December 31, 2022

Exhibits, page 64

 1. We understand from your response to prior comments that you prefer to limit compliance to future filings
of the annual report and future filings of the technical report summaries. However, we believe that you should obtain and file revised
technical report summaries in an amendment to the Form 20-F that is currently under review or no later than when your 2023 annual
report on Form 20-F if you are able to support a delay based on materiality. Please clarify your response relative to this timeframe.

Response:

The Company
acknowledges the Staff’s comment and respectfully advises that it plans to file Amendment No. 1 to the 2022
Form 20-F (the “2022 20-F Amendment”) with the Commission by no later than December 31, 2023 (unless
otherwise discussed with the Staff), in which it will (i) file as Exhibit 96.1 a revised technical report summary for the
Company’s US PGM property for the fiscal year ended December 31, 2021, incorporating indicative changes set out in the
September Response Letter; and (ii) file as Exhibit 96.7 a revised technical report summary for the Company’s
Keliber property for the fiscal year ended December 31, 2022 incorporating indicative changes set out herein and in the
September Response Letter (the “Amended 2022 Keliber Technical Report Summary”).

96.7 Technical
Report Summary of Keliber Lithium Project, page 65

 2. We note your response to prior comment 6 appears to be limited to proposed revisions that would reference
a 2021 Wood Mackenzie report and a March 2022 Fastmarkets report, though without providing the content pertaining to market studies
that is prescribed by Item 601(b)(96)(iii)(B)(16) of Regulation S-K.

The technical report summary should
include a detailed description of the commodity pricing and demand for the 4.5% spodumene concentrate along with any details that are
necessary to support the volumes of product and pricing used in the cash flow analysis.

Please further discuss these requirements
with the qualified persons involved in preparing the report and arrange to obtain and submit the revisions that are proposed.

Response:

The Company acknowledges the
Staff’s comments and will revise its disclosures to fully comply with Item 601(b)(96)(iii)(B)(16) of Regulation S-K in the Amended
2022 Keliber Technical Report Summary to be filed as Exhibit 96.7 to the 2022 20-F Amendment.

In Appendix A, the
Company has produced the revised market studies disclosure to be included as Section 15 of the Amended 2022 Keliber Technical Report
Summary (the “Amended Market Studies Disclosure”), which provides a detailed description of the commodity pricing and
demand for the 4.5% spodumene concentrate to support the volumes of product and pricing used in the cash flow analysis of the Amended
2022 Keliber Technical Report Summary. For the avoidance of doubt, the Amended Market Studies Disclosure will replace Section 15
of the technical report summary for the Keliber property for the fiscal year ended December 31, 2022 (the “2022 Keliber
Technical Report Summary”) in its entirety.

For completeness, the
Company has also reproduced Section 18 and Section 23.1 of the 2022 Keliber Technical Report Summary in Appendix A with
proposed additions highlighted in yellow, including those additions previously presented in the September Response Letter. All
indicative changes set out in Appendix A will be incorporated into the Amended 2022 Keliber Technical Report Summary to be filed as
Exhibit 96.7 to the 2022 20-F Amendment.

*****

If you have any
questions or further comments, please contact me at your earliest convenience at +27 11 278 9700.

    Sincerely,

    /s/ Charl Keyter

    Charl Keyter

    Chief Financial Officer

    Sibanye Stillwater Limited

    cc:
    Jacques le Roux, Sibanye Stillwater Limited

Robert Van Niekerk, Sibanye Stillwater Limited

Stephan Stander, Sibanye Stillwater Limited

Jeffrey Cohen, Linklaters LLP

Igor Rogovoy, Linklaters LLP

Lance Tomlinson, Ernst & Young Inc.

    Page 2 of 13

Appendix A

Amendments to Exhibit 96.7 – Keliber
Lithium Project Technical Report Summary

SEC Comment 2

Proposed amendments Section 15 (page 188
 – 189 of 2022 Keliber Technical Report Summary)

The Company will replace Section 15 in
its entirety with the following:

15 MARKET STUDIES

[§229.601(b)(96)(iii)(B)(16)]

The summary below is based on a 2021 Lithium Market
Study conducted for Kaustinen/Kokkola DFS, by Wood Mackenzie (the Wood Mackenzie Report), as well as an independent verification lithium
market study done by Fastmarkets. (2022) (the Fastmarkets Report). These market analyses cover the period up to 2031 (Wood Mackenzie)
and 2033 (Fastmarkets), for which reasonably accurate market supply and demand projections were available. This period will also coincide
with the bulk of the financial pay-back period for the Keliber project. Beyond 2031, market supply/demand information is scarcer and more
uncertain (less reliable) but given the significant trend in electrification and the growth in use of batteries in the electric vehicle
(EV) sector; coupled with the significant coinciding market deficit forecasted in 2031, it can reasonably be assumed that demand for lithium
derived products will persist, supporting the commercial production of spodumene concentrate.

15.1 Context

The Keliber project is a vertically integrated
project that includes the mining of spodumene ore, concentrating the ore and then conversion of spodumene concentrate into battery grade
lithium hydroxide. The concentrator will be sited at Paivaneva. From here the spodumene concentrate will be trucked to the Keliber owned
and operated ‘Cleantech’ Chemical Plant at Kokkola Industrial Park, where a battery grade lithium hydroxide monohydrate (LiOH.H2O)
will be produced along with analcime sand.

A series of tests were completed to determine
the production parameters of lithium hydroxide from spodumene ore, including the proprietary Metso-Outotec lithium hydroxide process at
pilot scale. This included a continuous hydrometallurgical pilot plant trial that was conducted at Metso-Outotec’s Pori Research
Centre from 7 to 24 January 2020 on converted Syväjärvi concentrate. There is sufficient evidence in the pilot plant results
to give confidence that the design recovery figure can be achieved in practice, following a suitable ramp-up period.

The Keliber project is likely to be the first
implementation of this specific lithium hydroxide flowsheet. While the individual unit processes are not novel, and while the Syväjärvi
(2020) and Rapasaari (2022) pilot trials have significantly de-risked the flowsheet, a residual risk remains, as it does with the first
example of any novel technology. Metso Outotec will also provide a process guarantee for the plant, although such a guarantee does not
ultimately guarantee a process that will work so much as it defines the extent of financial compensation that will apply should it not.
SEC Regulation S-K 1300 prohibits the declaration of Mineral Reserves based on novel/non-commercialized technology, and as such it should
be noted that the Mineral Reserves for Keliber have been declared based on production of a 4.5% spodumene concentrate, which was tailored
to suit the lithium hydroxide refinery, and that a ready market exists for the concentrate. Typical spodumene concentrates from pegmatite
orebodies grades closer to 6% spodumene, and the option exist for the Keliber project to make such a product. Given the intention to refine
all the concentrate at the Keliber refinery, no contracts have been entered into for the sale of the concentrate to be produced, and it
is assumed that the same terms, rates or charges could be obtained had the contract been negotiated at arm's length with an unaffiliated
third party.

    Page 3 of 13

15.2 Uses of Spodumene Concentrate

According to the Fastmarket Report, spodumene
concentrate is processed into lithium carbonate and lithium hydroxide. Their main industrial use is in the production of cathodes and
electrodes for rechargeable batteries. Lithium hydroxide is preferred in the battery manufacturing industries, especially in the EV production,
as it increases the performance of the battery, allowing EVs to have a higher usability range before needing a recharge. It is also used
as a thickener in lubricating grease as it is resistant to water and high temperatures and can sustain extreme pressures. Other uses for
lithium are in mobile phones, electronic devices, laptops, and digital cameras.

Figure 15.1 Global lithium usage by end-market
 – 2016, 2021 (%, LCE basis)

Looking forward, traditional applications are
expected to continue to grow each year at 1-3% in line with their respective sectors but should continue to lose market share to battery
demand. According to the Fastmarkets Report, traditional sectors are expected to consume 192.5 kt of LCE in 2033 – an increase of
3.0% compound average growth rate (CAGR) each year between 2021 and 2033. This compares to 3,102.4 kt of expected LCE demand in 2033 from
batteries for eMobility applications and energy storage solutions – annual increases of 22.3% CAGR over the same years.

15.3 Lithium Value Chain

Figure 15.2 below from the Wood Mackenzie Report,
provides an overview of the lithium value chain in 2020. Raw materials are shown in blue and brown, representing the source of refined
production and technical grade mineral products consumed directly in industrial applications. There are a number of refined lithium compounds,
shown in green. Refined products may be processed further into specialty lithium products, such as butyllithium or lithium metal, shown
in grey. Demand from major end-use applications is shown in orange with the relevant end-use sectors shown in yellow.

Of note is that spodumene concentrate, as a raw
material, predominantly gets converted into Lithium Carbonate and Lithium Hydroxide, for use in making batteries to support the automotive/transport
sector.

    Page 4 of 13

Figure
15.2 The lithium value chain

Within the Li-ion battery value chain, lithium
is used in manufacturing of cathode materials, electrolyte and anode materials, with cathodes accounting for 94% of total lithium consumption
in 2020. In 2020, roughly 52% of the global cathode market was divided between 15 first-tier manufacturers, including 8 manufacturers
from China, while the remaining 48% market share is divided between around 100 companies globally.

15.3 Supply and demand (Based on the Wood Mackenzie
Report)

In the case of absence of the ‘Cleantech’
Chemical Plant at Kokkola (which is planned to use all the spodumene concentrate from the Keliber project), the spodumene concentrate
will have to be sold into the international conversion market.

Demand

Demand for spodumene concentrate is driven by
a demand for lithium in the first instance.

Demand growth for lithium since 2009 has been
driven by the rapidly increasing use of lithium in rechargeable battery applications in the form of lithium carbonate and more recently
lithium hydroxide. From 2014-2020, demand growth for lithium has averaged 13.7% per year. The largest first use market for lithium is
rechargeable batteries, which accounted for 71% of global demand in 2020 and is expected to increase further beyond that. The next largest
first use market in 2020 was ceramics (7%), followed by glass-ceramics (6%). Other smaller first uses of lithium include greases, metallurgical
powders, glass, polymers, air treatment and primary batteries.

Demand growth for lithium in rechargeable batteries
averaged 29.6% per year between 2014-2020. Rechargeable batteries have accounted for over 50% of lithium demand each year since 2017.
Unlike most other major first-use applications, demand from rechargeable batteries continued to increase in 2020, despite disruption caused
by the COVID-19 pandemic and related lockdowns. With the exception of air treatment, where lithium use has fallen throughout the past
decade, all first-uses for lithium have also experienced growth over the period, albeit at slower rates than the rechargeable battery
sector.

The Wood Mackenzie Report forecasts global lithium
demand to increase by 19.8% per year in the 2020-2031 period, reaching a total of 2.84 Mt in 2031. Growth will be predominantly driven
by increasing battery production, with 2,733 GWh capacity required across all end-use applications by 2031. Regulation globally pushing
for stricter CO2 emissions limits by 2030 continues to force automotive original equipment manufacturers (OEMs) to shift to hybrid and
battery EVs (BEVs) models, a challenge which some OEMs have progressed with significantly since mid-2020, particularly in North America
and Europe. The use of Li-ion batteries in EVs is embedded into the growth trend, with little risk that a significant change in technology
will occur in the short to mid-term.

Longer term, the development of next-generation
battery technologies has the potential to both disrupt or accelerate lithium demand growth, dependent upon the prevalent technology.

    Page 5 of 13

The demand for lithium, by products, as demonstrated
in Figure 15.3, is dominated by lithium carbonate and lithium hydroxide, accounting for 70.9% of total demand in 2020. Battery-grade lithium
carbonate and hydroxide demand is forecast to increase by 16.6% per year and 25.9% per year respectively in the period to 2031, reaching
863.2 kt LCE and 1,646.1 kt LCE respectively. The preference in the automotive sector to increase vehicle range will inevitably shift
battery production toward nickel-rich chemistries, which in turn will see demand for lithium hydroxide increase faster than demand for
lithium carbonate.

Figure 15.3 Global demand for lithium by product,
2014 -2031 (Kt LCE)

In 2020, China was the largest consumer of lithium,
accounting for 63% of total demand or 243.1 kt LCE. Chinese demand has increased by 15.2% per year since 2014, largely through rapid expansion
of the domestic Li-ion battery sector with supplementary growth in industrial end-use markets. European demand has also risen significantly
in the period since 2014, with the majority of growth occurring in the period since 2018 with greater Li-ion battery manufacturing taking
place in the region.

European demand growth is strongly supported by
both government legislation and private investments with several battery