Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: Goldman Sachs appears to have had limited and unclear direct engagement with climate finance policies, while communicating some support for regulated corporate climate disclosures and opposition to stringent climate taxonomies and standards. Goldman Sachs takes a mixed position on the energy transition, supporting the use of fossil fuels in the energy mix but supporting government investments in renewable energy.
Top-line Messaging on Climate-Related Financial Policy: Goldman Sachs has stated support for the Paris Agreement, in its 2023 Sustainability Report, including action to keep temperature rise to 1.5C in its 2023 Task Force on Climate-related Financial Disclosures (TCFD) Report. Goldman Sachs posits a mixed position on climate-related finance regulation, suggesting in a December 2023 article that regulations should focus on encouraging financing the energy transition ‘rather than an increased regulatory burden’.
Position on Regulated Corporate Climate Disclosure: In April 2022, Goldman Sachs Asset Management's global head of stewardship told the Wall Street Journal that Goldman's voting framework is "very supportive of the SEC's proposed climate risk disclosure rules," suggesting support for the proposal. An insights report from February 2022 appears to support the need for policy to enhance disclosures in APAC to keep up with international ESG policy developments. A September 2022 memo regarding a meeting between banks and the Securities and Exchange Commission (SEC) suggests that Goldman Sachs does not support aspects of the SEC’s proposed climate disclosure rule, outlining concerns with implementation and cost. Goldman Sachs Asset Management expressed support for the ISSB in its 2022 Stewardship Report. In Goldman Sachs 2023 Sustainability Report however, Goldman Sachs did not take a clear position on mandatory corporate climate disclosure, though emphasized the "extensive" disclosures to be required under EU Corporate Sustainability Reporting Directive (CSRD).
Position on Taxonomies: Goldman Sachs appears to have an unsupportive position on taxonomies. In a January 2022 insights report, Goldman Sachs supported the weakening] of EU Taxonomy criteria to include natural gas and in a February 2022 insights report it suggested that concerns of greenwashing following the inclusion of gas in the taxonomy were “overdone.”
Position on Incorporating Climate Factors Into Investor Duties: Goldman Sachs Asset Management, in a January 2022 article, expressed an unclear position on the US Department of Labor’s proposed Prudence and Loyalty rule. Goldman Sachs appears to support the weakening of the EU Sustainable Finance Disclosure Regulation (SFDR), suggesting in a March 2022 website article that minimum Article 8 and 9 fund standards could "threaten ESG fund innovation" and restrict capital from companies that "need to transition the most". Similarly, in a September 2022 meeting with the European Securities and Markets Authority Goldman Sachs suggested that the ‘Do No Significant Harm’ (DNSH) principle should recognize improvement on indicators of adverse impact over time and suggested that the EU's approach was 'overly-conservative'.
Position on Real Economy Climate Policy: Goldman Sachs has advocated for carbon pricing in both December 2023 Goldman Sachs Principles for Responsible Banking Report and in a meeting with the European Commission in November 2023.
Position on Energy, Industry, and Land Transitions: Goldman Sachs takes a mixed position on the transition of energy mix. David Solomon, Goldman Sachs CEO, expressed opposition for the transition of the energy mix away from fossil fuels in a September 2023 energy summit. In Goldman Sachs’ 2023 Sustainability report however, Solomon emphasized the costs in transition towards a low carbon economy and flagged increased demand from AI as a headwind, but advocated for government policy to decarbonize in a way that balances energy security and economic growth. Similarly, Goldman Sachs has taken mixed positions on carbon capture and sequestration (CCS). In its Sustainability Report Goldman Sachs supported the use of CCS in hard to abate sectors, however in a February 2024 video Goldman Sachs stated that ‘oil and gas is net a social good’ and supported CCS as sufficient for decarbonizing the energy mix while maintaining current fossil fuel production. Goldman Sachs expressed support for the Inflation Reduction Act in an April 2023 article and the European Green Deal in its 2022 Sustainability Report. Goldman Sachs has also engaged on the energy transition at EU level, meeting with representatives from the European Commission in January 2024, though details of this meeting are unclear.
Industry Association Governance: In its Statement on Policy Engagement and Political Participation, Goldman Sachs discloses just three trade associations to which it holds membership. Goldman Sachs Asset Management lists other memberships in reports across its website. Neither Goldman Sachs nor its asset management arm describe the sustainable finance policy positions of these associations or any details of their policy engagement.
InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically. This summary was last updated in Q4 2024.