Why Goldman Sachs Shareholders Should Vote FOR Proposal 7
On April 29, shareholders of Goldman Sachs (ticker: GS) will vote on Proposal #7 – a request for comprehensive disclosure of the firm’s lobbying activities.
At Newground, we view this as a pragmatic and necessary step toward stronger governance and more resilient long-term value creation.
Below is a summary of the main reasons shareholders should support this common-sense governance reform. You can download Newground's full proxy memo [PDF] which lays out detailed arguments with citations of supporting evidence.
The Issue: A Material Transparency Gap
Goldman Sachs spent nearly $4 million on lobbying in 2025 alone, and $55.7 million since 2010 – yet shareholders lack a clear, consolidated view of who receives that money and whether its use aligns with the firm’s stated priorities.
Proposal 7 seeks an annual report that discloses:
- Direct lobbying expenditures (federal and state)
- Indirect lobbying via trade associations and social welfare groups
- Sufficient detail for shareholders to evaluate alignment and risk
This is not a novel or burdensome request. It is a baseline expectation of modern governance.
Why This Matters
1. Reputation Risk Is Financial Risk
Reputation is no longer intangible – it is a measurable component of enterprise value. The memo highlights that reputation may account for ~38% of market capitalization in major indices.
When lobbying activities are opaque, companies expose themselves to:
- Misalignment with stated values
- Public controversy
- Erosion of stakeholder trust
Each of these carries direct financial consequences.
2. Current Disclosure Is Incomplete
Goldman provides no consolidated reporting on lobbying activities. Information is fragmented, difficult to access, and omits key categories – particularly at the state level and across third-party channels.
For investors, this creates a simple problem: you cannot evaluate what you cannot see.
3. “Dark Money” Creates Unexamined Risk
A central concern is indirect lobbying – funds routed through trade associations and 501(c)(4) so-called “social welfare” organizations.
These channels:
- Allow unlimited spending
- Often lack disclosure requirements
- Can be used in ways that diverge from corporate commitments
The memo notes that such indirect spending may be at least double what is publicly reported.
For shareholders, this is not a political issue, it is a governance blind spot.
4. Goldman Lags Behind Its Peers
Goldman Sachs does not fully disclose its trade association memberships or related spending, placing it behind peer institutions such as Bank of America, Citigroup, and JPMorgan Chase.
In a sector where trust and credibility are paramount, lagging disclosure is itself a risk signal.
5. The Cost Argument Does Not Hold
Goldman's board argues that additional reporting would be burdensome. Yet the firm already collects this information for both internal and regulatory purposes.
As the memo makes clear: this is not about generating new data — it is about organizing and sharing existing data.
A Constructive Path Forward
Proposal 7 does not dictate policy positions or constrain business strategy. It asks for transparency – nothing more, nothing less.
And transparency has a well-understood effect: what gets disclosed gets managed.
For a firm of Goldman Sachs’ stature, this is an opportunity to lead – to align its practices with its stated commitments and to strengthen investor confidence.
The Bottom Line
Supporting Proposal 7 is a vote for:
- Better risk oversight
- Stronger governance
- More informed capital allocation
We encourage shareholders to vote FOR Proposal #7 ahead of the April 29 AGM.
Read the full proxy memo: https://www.iccr.org/wp-content/uploads/2026/04/GS_2026_Proxy-Memo_FINAL_2026.0414.pdf
Note: This material is intended for educational purposes only. As with all our public writing, blog posts do not constitute tax or financial planning advice; likewise, they are neither an offer to sell nor solicitation to buy any investment or security.
