Randgold Resources Limited
3rd Floor, Unity Chambers
28 Halkett Street
St. Helier, Jersey JE2 4WJ
Channel Islands
September 5, 2017
BY EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Rufus Decker, Accounting Branch Chief Office of Beverages, Apparel and Mining |
| Re: | Randgold Resources Limited |
| Form 20-F for the Fiscal Year Ended December 31, 2016 | |
| Filed March 28, 2017 | |
| File No. 000-49888 |
Ladies and Gentlemen:
We refer to the comment letter, dated August 14, 2017, from the staff of the Division of Corporation Finance (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”), in respect of the Annual Report on Form 20-F, for the fiscal year ended December 31, 2016, of Randgold Resources Limited (the “Company”) filed with the Commission on March 28, 2017. Set forth below in detail is the response to the Staff’s comment, which has been provided following the text of the comment in the Staff letter:
Item 3. Key Information
A. Selected Financial Data
Non-GAAP Information, page 7
| 1. | We have reviewed your response to comment 1. You appear to be multiplying amounts in the financial results for the Kibali Mine and the Morila Mine by your ownership percentage in these joint ventures. Under the equity method of accounting, you own an interest in the investee as a whole and do not have a proportionate legal interest in each financial statement line item, like revenues or expenses. Thus, we continue to believe that reflecting these joint ventures using a proportionate consolidation method in your consolidated non-GAAP measures does not appear to be consistent with the guidance in Question 100.04 of the updated Non-GAAP Compliance and Disclosure Interpretations issued on May 17, 2016. Please revise your consolidated non-GAAP disclosures accordingly. |
Rufus Decker U.S. Securities and Exchange Commission Division of Corporation Finance September 5, 2017 |
Response:
We hereby advise the Staff that the Company will comply with the Staff’s comment, and in future filings the Company will revise its disclosures such that no consolidated non-GAAP financial measures are presented which include joint venture investments accounted for under the equity method of accounting.
If you have any questions regarding the Company’s response or would like to discuss any of its views further, please feel free to contact me at +44 1534 735 333 or contact Steven Suzzan of Norton Rose Fulbright US LLP at (212) 318-3092.
| Yours faithfully, | |
| /s/ Graham Shuttleworth | |
| Graham Shuttleworth | |
| Chief Financial Officer | |
| Randgold Resources Limited |
| cc: | Angela Lumley |
| Steven Suzzan, Esq., Norton Rose Fulbright US LLP |
