Goldman Sachs Group Inc/The – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Goldman Sachs describes a structured governance process for overseeing its policy advocacy, but the disclosures suggest only partial integration of climate-specific alignment checks. The company states that “Staff in the Office of Government Affairs (OGA), Compliance and Legal departments is responsible for the review and approval process” and that OGA “coordinates on an ongoing basis with our business unit leadership… to identify legislative and regulatory priorities,” indicating an internal mechanism for pre-clearing direct lobbying positions. Indirect lobbying is also subject to review: “Staff in the OGA, Compliance and Legal departments reviews and approves these memberships to ensure that they are consistent with relevant public policy objectives,” and “a comprehensive report on our memberships… is reviewed by our Executive Vice President… and by our Board’s Public Responsibilities Committee on an annual basis,” showing a board-level check on trade-association activity. Climate topics are referenced in the company’s advocacy focus—“We remain focused on advocating for core principles… including carbon pricing and thoughtful policy, which support the private sector’s role in helping to drive the climate transition”—suggesting that climate considerations are included in its public-policy agenda. Oversight responsibility is clearly assigned: “our Board is apprised of, and engaged in, the policy issues we focus on,” and the Board’s Public Responsibilities Committee “reviews an annual report regarding our lobbying expenditures.” However, the disclosures do not specify criteria or a formal procedure for testing whether either direct or trade-association lobbying is aligned with the firm’s climate commitments, nor do they describe actions taken when misalignment is identified, acknowledging instead that “there may be instances where an association’s positions on certain issues may diverge from our views.” We found no evidence of a published climate-lobbying alignment report or of a routine audit that evaluates and discloses the consistency of lobbying positions with Paris-aligned goals. This indicates that while governance structures and senior oversight exist, the company has not fully demonstrated an explicit, systematic process for ensuring that all lobbying—especially through third-party associations—is aligned with its climate strategy. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Goldman Sachs describes a structured governance process for overseeing its policy advocacy, but the disclosures suggest only partial integration of climate-specific alignment checks. The company states that “Staff in the Office of Government Affairs (OGA), Compliance and Legal departments is responsible for the review and approval process” and that OGA “coordinates on an ongoing basis with our business unit leadership… to identify legislative and regulatory priorities,” indicating an internal mechanism for pre-clearing direct lobbying positions. Indirect lobbying is also subject to review: “Staff in the OGA, Compliance and Legal departments reviews and approves these memberships to ensure that they are consistent with relevant public policy objectives,” and “a comprehensive report on our memberships… is reviewed by our Executive Vice President… and by our Board’s Public Responsibilities Committee on an annual basis,” showing a board-level check on trade-association activity. Climate topics are referenced in the company’s advocacy focus—“We remain focused on advocating for core principles… including carbon pricing and thoughtful policy, which support the private sector’s role in helping to drive the climate transition”—suggesting that climate considerations are included in its public-policy agenda. Oversight responsibility is clearly assigned: “our Board is apprised of, and engaged in, the policy issues we focus on,” and the Board’s Public Responsibilities Committee “reviews an annual report regarding our lobbying expenditures.” However, the disclosures do not specify criteria or a formal procedure for testing whether either direct or trade-association lobbying is aligned with the firm’s climate commitments, nor do they describe actions taken when misalignment is identified, acknowledging instead that “there may be instances where an association’s positions on certain issues may diverge from our views.” We found no evidence of a published climate-lobbying alignment report or of a routine audit that evaluates and discloses the consistency of lobbying positions with Paris-aligned goals. This indicates that while governance structures and senior oversight exist, the company has not fully demonstrated an explicit, systematic process for ensuring that all lobbying—especially through third-party associations—is aligned with its climate strategy.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Goldman Sachs offers only limited transparency around its climate-related lobbying. It refers to broad policy areas such as carbon pricing, the Paris Agreement and the need for “thoughtful public policy” but does not name any specific pieces of climate legislation or regulations it has tried to influence. The firm does note several ways it engages, mentioning “direct advocacy on certain public policy issues,” participation in trade associations like SIFMA and the American Bankers Association, membership of initiatives such as the Net-Zero Banking Alliance, and its Office of Government & Regulatory Affairs that manages relationships with “regulatory and legislative officials globally,” yet it does not identify which regulators, ministries or lawmakers are contacted or describe concrete activities such as meetings or submissions. Desired outcomes are framed in very general terms—support for “a price on carbon,” “long-term incentives for investment in sustainable solutions,” and revision of the proposed U.S. Basel III reforms—but the company does not spell out the precise changes it seeks or the metrics it is aiming for. Because the disclosures stay at a high level and omit specific policies, targets and lobbying actions, the visibility into the firm’s climate lobbying remains limited.	D