Shareholders to Goldman Sachs: Disclose Lobbying Expenses
Newground Social Investment filed a shareholder proposal that calls on Goldman Sachs (ticker: GS) to expand its public disclosure of the money it spends on lobbying.
While lobbying can support positive policy changes for a company, it can also create significant costs and risks. Generally speaking, the key is whether it's done in the light of day – i.e., is it done openly and transparently?
Since it's their money, shareholders have a right to know how funds are being spent on efforts to influence public policy – whether through direct lobbying or indirectly through the efforts of trade associations. Lobbying transparency helps a company's owners – the stockholders – ensure that management behaves in alignment with shareholder interest; such transparency is increasingly considered a best-practice among leading corporations. Given that companies already track where and how expenditures are being made, the many companies who already do disclose report that making these figures transparent to stockholders is not an operational burden. Thus, Goldman should join other corporate leaders like Amazon, American Express, US Bancorp, and Walmart by expanding its lobbying disclosure.
The full text of Newground's proposal appears below, and is also available in its original format as a downloadable PDF. In May 2026 it will appear on the proxy for a vote at the company's annual meeting of shareholders.
Lobbying Disclosure
RESOLVED: Shareholders of Goldman Sachs Group, Inc. (“Goldman” or “Goldman Sachs”) request the preparation of a report that is updated annually, omits proprietary data, and is produced at reasonable cost, which discloses:
- Payments made by Goldman Sachs that are used for direct or indirect lobbying; in each indirect case including the amount of the payment as well as the recipient.
For purposes of this proposal, payments used for direct lobbying are the annual aggregate amounts reported at the federal and state levels, broken out by federal and individual state.
Payments used for indirect lobbying are payments to trade associations or social welfare groups that are used for lobbying, as defined by tax law. Both direct and indirect lobbying include efforts at the state and federal levels.
The report shall be posted on the Goldman Sachs website.
Supporting Statement
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.
--------------------
SOURCES
1. www.ncsl.org/ethics/how-states-define-lobbying-and-lobbyist
~ ~ ~
PHOTO CREDIT: 2211473abhijithsaravanan, CC BY-SA 4.0, via Wikimedia Commons
Note: This material is intended for educational purposes only. As with all our public writing, blog posts do not constitute tax, financial planning, or investment advice. Likewise, they are neither an offer to sell nor solicitation to buy any investment or security.
