THE GOLDMAN SACHS GROUP, INC. | Improve transparency in regard to lobbying at THE GOLDMAN SACHS GROUP, INC.

35.58% votes in favour
AGM date
Previous AGM date
Proposal number
Resolution details
Company ticker
Lead filer
Resolution ask
Report on or disclose
ESG theme
  • Governance
ESG sub-theme
  • Lobbying / political engagement
Type of vote
Shareholder proposal
Filer type
Company sector
Company HQ country
United States
Resolved clause
Resolved, the shareholders of Goldman request the preparation of a report, updated annually, disclosing:
1. Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communication
2. Payments by Goldman used for (a) direct or indirect lobbying or (b) grassroots lobbying communications, in each case including the amount of the payment and the recipient.
3. Goldman’s membership in and payments to any tax-exempt organization that writes and endorses model legislation.
4. Description of management’s and the Board’s decision-making process and oversight for making payments described in sections 2 and 3 above.

For purposes of this proposal, a “grassroots lobbying communication” is a communication directed to the general public that (a) refers “to specific legislation or regulation, (b) reflects a view on the legislation or regulation and (c) encourages the recipient of the communication to take action with respect to the legislation or regulation. “Indirect lobbying” is lobbying engaged in by a trade association or other organization of which Goldman is a member.
Both “direct and indirect lobbying” and “grassroots lobbying communications” include efforts at the local, state and federal levels.`
The report shall be presented to the Public Responsibilities Committee and posted on Goldman’s website.
Whereas clause
Whereas, full disclosure of Goldman Sachs Group’s lobbying activities and expenditures to assess whether Goldman’s lobbying is consistent with its expressed goals and shareholders’ interests.
Supporting statement
John Chevedden, 2215 Nelson Avenue, No. 205, Redondo Beach, California 90278, beneficial owner of at least $2,000 in market value of the company’s Common Stock for at least three years, is the proponent of the following shareholder proposal.
Goldman spent $41 million from 2010 — 2021 on federal lobbying. This does not include state lobbying, where Goldman also lobbies. Goldman also lobbies abroad, spending between €800,000 — 899,999 on lobbying in Europe for 2021 and previously drawing scrutiny. for “allegedly trying to lobby members of the European Commission.”1

Companies can give unlimited amounts to third party groups that spend millions on lobbying and undisclosed grassroots activity. These groups may be spending “at least double what’s publicly reported.”2 Goldman fails to disclose its memberships in or payments to trade associations and social welfare organizations, or the amounts used for lobbying, to shareholders. Goldman belongs to the American Bankers Association (ABA), Business Roundtable, Financial Service Forum (FSF), Managed Funds Association and Securities Industry and Financial Markets Association, which together spent $55 million on lobbying for 2021.

Goldman’s lack of disclosure presents reputational risks when its lobbying contradicts company public positions. For example, Goldman publicly supports addressing climate change, yet the Business Roundtable opposed the Inflation Reduction Act and its historic investments in climate action3 and FSF lobbied the Securities and Exchange Commission to weaken proposed climate disclosure rules.4 And while Goldman does not belong to or support the American Legislative Exchange Council, which is attacking “woke capitalism,”5 one of its trade associations does, as ABA supported its 2022 annual meeting.6 According to the 2022 Harris Corporate Reputation Survey, Goldman ranked 80” of the 100 most visible US companies.7
Reputational damage stemming from these misalignments could harm shareholder value, and I urge Goldman to expand its lobbying disclosure.

How other organisations have declared their voting intentions

Organisation name Declared voting intentions Rationale
Anima Sgr For As additional disclosure of the company's direct and indirect lobbying payments would help shareholders better assess the risks and benefits associated with the company's participation in the public policy process.
Although Goldman Sachs has transparent disclosure of its lobbying oversight and policy priorities, it does not provide sufficient information for shareholders to assess its direct or indirect lobbying payments, including to its trade associations. Providing links to publicly available lobbying reports is not sufficient for shareholders to efficiently assess the company’s lobbying spending.
Rothschild & co Asset Management For
KBI Global Investors For

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