John Reynolds Assistant Director Office of Beverages, Apparel and Mining United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington D.C. 20549 – 7010 United States of America | Gold Fields Limited Reg. 1968/004880/06 150 Helen Road, Sandown, Sandton, 2196
Postnet Suite 252 Private Bag X30500 Houghton, 2041 South Africa
Tel +27 11562-9700 Fax +27 86 720 2704 www.goldfields.com |
July 8, 2019
By EDGAR
Dear Mr. Reynolds,
RE: | Gold Fields Limited |
Form20-F for the year ended December 31, 2018
Filed on March 29, 2019
File No. 001-31318
We refer to the comment letter (the “Comment Letter”) dated June 17, 2019 of the staff (“Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) on the above referenced Form20-F (the “2018Form20-F”) of Gold Fields Limited (“Gold Fields”). For your convenience, the comment is repeated below, prior to the response.
Engineering Comment
1 | Further Information/Reserve Statement, page 68 |
Proven and probable reserves are disclosed for your Salares Norte, Cerro Corona, and Demang [sic] properties. Please forward to our engineer as supplemental information and not as part of your filing, your information that establishes the legal, technical, and economic feasibility of your materials designated as reserves, as required by Industry Guide 7(c).
To minimize the transfer of paper, please provide the requested information on a CD or a flash drive, formatted as Adobe PDF files and provide the name and phone number for a technical person our engineer may call, if he has technical questions about your reserves.
In the event your company desires the return of this supplemental material, please make a written request with the letter of transmittal and include apre-paid,pre-addressed shipping label to facilitate the return of the supplemental information. Please note that you may request the return of this information pursuant to the provisions of Rule12b-4 of the Exchange Act.
If there are any questions concerning the above request, please phone Mr. George K. Schuler, Mining Engineer at (202)551-3718.
Directors: C A Carolus (Chair), N J Holland†** (Chief Executive Officer), P A Schmidt** (Chief Financial Officer), A Andani#, P J Bacchus†, T P Goodlace, C E Letton^, P Mahanyele-Dabengwa, R P Menell, S P Reid^, Y G H Suleman
^Australian,†British,#Ghanaian,** Executive Director
Company Secretary: T L Harmse (Acting)
Response
Gold Fields acknowledges the Staff’s comment and wishes to advise the Staff that it has supplied the requested information regarding the materials designated as reserves at the properties noted above in the requested format to George K. Schuler, Mining Engineer under separate cover. If Mr. Schuler or other members of the Staff have any questions regarding our reserves, they should feel free to contact:
Tim Rowland
Vice President: Group Geology, Resource Estimation and Planning
Cell: 011 27 82 441 3181
Tel: 011 27 11 562 9919
Email: tim.rowland@goldfields.com
In the alternative, they should also feel free to contact Taryn Harmse (tel: 011 27 11 562 9724; email: taryn.harmse@goldfields.com) of Gold Fields or Thomas B. Shropshire, Jr. (tel: 011 44 20 7456 3223; email: tom.shropshire@linklaters.com) or John Stone (tel: 011 44 20 7456 2677; email: john.stone@linklaters.com) of Linklaters LLP.
Gold Fields hereby requests the return of the supplied supplemental information provided to the Staff pursuant to Rule12b-4 under the Securities Exchange Act of 1934.
Supplemental Information
Gold Fields hereby acknowledges (i) it is responsible for the adequacy and accuracy of the disclosures in the filing, (ii) 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 (iii) it 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.
* * * * *
Should you or the Staff have any questions or require any additional information, please contact the undersigned at 011 27 11 562 9796 or viae-mail at pschmidt@goldfields.co.za.
Yours sincerely,
/s/ Paul Schmidt
Paul Schmidt
Chief Financial Officer
Gold Fields Limited
cc: | George K. Schuler, Securities and Exchange Commission |
Pam Howell, Securities and Exchange Commission
Taryn Harmse, Gold Fields Limited
Thomas B. Shropshire, Jr., Linklaters LLP