Goldman Sachs Asset Management | Transparency in lobbying report at Goldman Sachs Asset Management

Status
AGM passed
AGM date
Previous AGM date
Proposal number
5
Resolution details
Company ticker
NYSE: GS
Lead filer
Individual
Resolution ask
Report on or disclose
ESG theme
  • Governance
ESG sub-theme
  • Lobbying / political engagement
Type of vote
Shareholder proposal
Filer type
Shareholder
Company sector
Financials
Company HQ country
United States
Resolved clause
Resolved: Shareholders request the preparation of a report, updated annually, disclosing:
1. Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications.
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 ad the Board's decision-making process and oversight for making payments described in sections 2 and 3.

For purposes of this proposal, a "grassroots lobbying communication" is a communication directed to the general public that (a) refers to a 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.
Supporting statement
Supporting Statement: Full disclosure of Goldman's lobbying activities and expenditures is needed to asses whether Goldman's lobbying is consistent with its expressed goals and shareholders' interests. Goldman spent $44 million from 2010-2022 on federal lobbying. This does not include state lobbying, where Goldman also lobbies. Goldman also lobbies abroad, spending between €800,00-899,999 on lobbying in Europe for 2022 and drawing scrutiny for hiring JPMorgan's chief lobbyist in Europe.

Companies can give unlimited amounts to third party groups that spend millions on lobbying and undisclosed grassroots activity. Goldman fails to disclose its memberships in or payments to trade associations and social welfare groups, or the amounts used for lobbying, to shareholders. Goldman belongs to the American Bankers Association ()ABA), Bank Policy Institute (BPI), Business Roundtable, Financial Service Forum (FSF), Managed Funds Association and Securities Industry and Financial Markets Association, which together spent $46 million on federal lobbying for 2022.

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 action, and BPI and FSF both lobbied the Securities and Exchange Commission to weaken proposed climate disclosure rules. A recent analysis looking at inconsistencies between banks' public climate commitments and their direct and indirect climate lobbying practices noted Goldman failed to publicly support the Inflation Reduction Act. And while Goldman does not belong to or support the American Legislative Exchange Council, which is attacked "woke" investing, one of its trade associations does, as ABA supported its 2022 annual meeting.

Reputational damage stemming from these misalignments could harm shareholder value. Thus it is a best practice for Goldman to expand its lobbying disclosure.

Filed by John Chevedden

How other organisations have declared their voting intentions

Organisation name Declared voting intentions Rationale
VidaCaixa For
Legal & General Investment Management (Holdings) For A detailed explanation for our vote intention can be found on the LGIM Blog: https://blog.lgim.com/categories/esg-and-long-term-themes/lgims-voting-intentions-for-2024/

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