Goldman Sachs Group Inc/The

Lobbying Governance

AI Extracted Evidence Snippet Source

As a global financial institution, we recognize the importance of multi-stakeholder engagement with trade associations, industry groups, and policymakers to advance our commercial priorities and our clients' objectives. Our participation in various trade associations, industry groups, and initiatives supports our ultimate goal of managing risk and creating value for our clients and our firm. Our participation does not indicate that we are in complete agreement with the entirety of each group's stated policies. Rather, we participate in such groups and initiatives to the extent that their objectives align with our own commercial priorities and the needs of our clients. We aim to contribute our expertise to these organizations and leverage their input where doing so is consistent with our policies and appropriate for our firm. Memberships and Engagement Consistent with the principles and limitations described immediately above, we participate in a number of climate- and/ or sustainability-focused initiatives and organizations, including the UN Principles for Responsible Banking, UN Principles for Responsible Investing, RMI's Center for Climate- Aligned Finance, and Net Zero Banking Alliance. Public Policy Advocacy Goldman Sachs participates in direct advocacy on certain public policy issues we believe foster global economic growth, promote financial stability, and improve communities and society, all of which impact our firm, our clients, capital markets, and the general economy. As part of our engagement in the public policy process, we participate in several trade organizations and industry groups, such as the Financial Services Forum, Bank Policy Institute, Securities Industry Financial Markets Association, Asia Securities Industry & Financial Markets Association, Association for Financial Markets in Europe, Council of Institutional Investors, American Bankers Association, Institute of International Finance, and International Swaps and Derivatives Association, among others RMI We are a founding partner of the Center for Climate- Aligned Finance, which was established by the RMI in July 2020 to help the financial sector transition the global economy toward a zero carbon, 1.5°C future. With deep partnerships in finance, industry, government, and civil society, the center works to develop de-carbonization agreements within high- emitting sectors, build global frameworks for climate alignment, and support financial institutions in decarbonizing their lending and investing. 2023 was also a landmark year for sustainable finance regulation in the US and across the world. As we continue to support our clients as they look to adapt to these developments and also assess potential impacts of public policy on our own business, we engage with policymakers and industry associations on issues of importance to our firm, our clients, and the global communities in which we work. We remain focused on advocating for core principles across issues of importance to us and our clients, including carbon pricing and thoughtful policy, which support the private sector's role in helping to drive the climate transition.

https://www.goldmansachs.com/investor-relations/corporate-governance/sustainability-reporting-new/principles-for-responsible-banking-report.pdf

###### Governance Overview

We remain committed to formalising an effective and resilient governance and risk environment for climate- and sustainability-related issues. To achieve this, alongside embedding climate-related risks into our risk management practices, we continue to formalise our governance and oversight of climate- related risks and opportunities. In 2023, for example, the move of the UK GS Alternatives business from GSI to GSAMI allowed governance to be aligned more effectively across public and private markets investing activities.

Our governance includes board-level oversight at the firmwide and legal entity levels as well as internal governance structures and responsibilities across our management teams and specific functional groups. Our governance and oversight continue to evolve, including in response to increasing demand for reporting and transparency from key stakeholders and regulators.

Firmwide Governance

In this section of the report, we provide detail on Goldman Sachs Board-level oversight and other firmwide internal governance structures that play a critical role in overseeing climate-related risks and opportunities across Goldman Sachs.

Firmwide Board Oversight

The Goldman Sachs Board and its committees play a critical role in overseeing firmwide risks, including with respect to climate matters.

**Goldman Sachs Board of Directors**
**(the Goldman Sachs Board)**

**Risk Committee of**
**the Goldman Sachs Board**

**Public Responsibilities Committee**
**of the Goldman Sachs Board**

Goldman Sachs Board of Directors (the Goldman Sachs Board) and its committees are responsible
for overseeing the business and affairs of the firm, including oversight of the management of the
firm's most significant risks. Given the interdisciplinary nature of the oversight of sustainability
risks, including climate-related risks, the Board carries out its oversight of these matters directly, at
the full Board level, as well as through its committees, including its Risk and Public Responsibilities
Committees. This may include periodic updates on the firm's sustainability strategy and initiatives,
as well as targets, progress, and incentives related thereto, discussions regarding the climate models
the firm utilises to assess physical and transition risks, and reviews of our sustainability- and
climate-related reporting.

The Risk Committee of the Goldman Sachs Board (the Risk Committee) oversees firmwide financial
and nonfinancial risks. This includes the firm's overall risk-taking tolerance and risk governance,
including with respect to climate risk. As part of its oversight, the Risk Committee receives periodic
updates on our climate risk management approach, including scenario analysis capabilities and
integration into existing risk management processes.

The Public Responsibilities Committee (PRC) of the Goldman Sachs Board assists the Board in its
oversight of our firmwide sustainability strategy and sustainability issues affecting the firm, including
climate change. As part of its oversight, the PRC receives periodic updates on our sustainability
strategy and reporting. The PRC also periodically reviews our governance and related policies and
processes for sustainability- and climate-related matters.

https://www.goldmansachs.com/investor-relations/corporate-governance/sustainability-reporting/2023-awm-tcfd-report.pdf

In addition, our Board is apprised of, and engaged in, the policy issues we focus on and our efforts in this regard. [...] Staff in the Office of Government Affairs ("OGA"), Compliance and Legal departments is responsible for the review and approval process. [...] Staff in OGA is responsible for coordinating our global public policy priorities. Staff in OGA coordinates on an ongoing basis with our business unit leadership and our Compliance and Legal departments to identify legislative and regulatory priorities, both regionally and globally. Staff in OGA vets overall public policy priorities and related advocacy efforts with senior management. [...] Additionally, our Board's Public Responsibilities Committee reviews an annual report regarding our lobbying expenditures. [...] Staff in the OGA, Compliance and Legal departments reviews and approves these memberships to ensure that they are consistent with relevant public policy objectives; however, because these associations are supported by, and represent, many other companies and groups, there may be instances where an association's positions on certain issues may diverge from our views. [...] A comprehensive report on our memberships, including membership fees and dues paid in excess of $30,000, is reviewed by our Executive Vice President, Chief of Staff and Secretary to the Board and by our Board's Public Responsibilities Committee on an annual basis. Dues attributable to lobbying by United States trade associations are included in the quarterly reports we file pursuant to the Lobbying Disclosure Act.

https://www.goldmansachs.com/investor-relations/corporate-governance/corporate-governance-documents/political-statement.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]2021 was also a landmark year for sustainable finance regulation in the US and across the world. As we continue to support our clients as they look to adapt to these developments and also assess potential impacts of public policy on our own business, we engage with policymakers and industry associations on issues of importance to our firm, our clients, and the global communities in which we work. We remain focused on advocating for core principles across issues of importance to us and our clients, including carbon pricing and thoughtful policy, which support the private sector's role in helping to drive the climate transition. For more information, please see the Goldman Sachs Sustainability Report 2021: Progress through performance.

CDP Questionnaire Response 2022

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]We engage directly and indirectly with policy makers. 2022 was also a landmark year for sustainable finance regulation in the US and across the world. As we continue to support our clients as they look to adapt to these developments and also assess potential impacts of public policy on our own business, we engage with policymakers and industry associations on issues of importance to our firm, our clients, and the global communities in which we work. We remain focused on advocating for core principles across issues of importance to us and our clients, including carbon pricing and thoughtful policy, which support the private sector's role in helping to drive the climate transition. For more information, please see the Goldman Sachs Sustainability Report 2022.

CDP Questionnaire Response 2023