As long-term shareholders of Goldman Sachs, we support transparency and accountability in corporate lobbying. Companies and investors may benefit if lobbying leads to improved policies, reduced regulation or taxation, or governmental contracts or subsidies. However, lobbying activities also create costs and can create risks for a corporation – and, by extension, their shareholders. Currently, to assemble any kind of picture of a company’s lobbying, shareholders must search both federal and 50 individual state lobbying databases. But a complete picture is not possible because state disclosure requirements vary widely;1 for instance, an analysis of one company’s disclosures revealed that 25 out of 48 states did not disclose amounts spent.2 In 2024, Goldman Sachs spent $2.74 million on federal lobbying alone – but this figure does not include state lobbying, where Goldman also lobbies. Goldman fails to even list its trade associations, much less the amounts it pays to those trade associations that are then used for lobbying. Similarly, it fails to disclose the amount of payments made to social welfare groups, that are then used for lobbying. The International Corporate Governance Network policy on lobbying recommends that a company commit to public disclosure of its lobbying activities as well as any direct or indirect expenditure beyond a de minimis level (e.g., a contribution equal to or less than $10,000). Many companies provide this kind of annual lobbying reporting to shareholders, including Cardinal Health, Exxon, Procter & Gamble, and Xcel Energy – each of which report on their federal and state lobbying, along with indirect lobbying through trade associations and social welfare groups; Amazon and Walmart – which provide full state lobbying reports; and American Express, Ameriprise Financial, and US Bancorp – which provide an annual report of trade association payments used for lobbying. Companies are required to report this information at the federal and state levels, so it is not burdensome to also report it to shareholders. THEREFORE: We urge Goldman Sachs to expand its lobbying disclosure. 1 www.ncsl.org/ethics/how-states-define-lobbying-and-lobbyist 2 www.citizen.org/news/despite-company-claims-eli-lilly-fails-to-disclose-its-state-lobbying-spending-for-half-the-country