NLPC presented a shareholder proposal on Wednesday at Goldman Sachs‘s 2025 annual meeting of shareholders that asked the company to drop diversity, equity, and inclusion goals from its executive pay incentives. NLPC argued that these DEI goals steer the company in a politicized direction, deprioritize merit in its talent pool, and increase legal risk.
The company’s board of directors opposed our proposal, as explained on page 87 of its proxy statement. NLPC’s response to the board’s opposition statement was filed with the Securities and Exchange Commission last month.
Presenting the proposal at the meeting was Luke Perlot, associate director of NLPC’s Corporate Integrity Project. A transcript of his four-minute remarks follows:
Good morning.
In recent months, Goldman Sachs has taken meaningful steps to roll back its DEI programs – which should be no surprise given the widespread backlash against DEI that is spreading across corporate America. However, the Company still has a ways to go.
Our proposal asks the Board’s Talent and Compensation Committee to revisit – and potentially eliminate – diversity, equity & inclusion goals that are currently included in the compensation packages for the Company’s named executive officers. Put simply, we are asking Goldman Sachs to reward executives not for meeting politically motivated hiring or promotion quotas, but for genuine business performance.
In the wake of George Floyd’s death in May 2020, corporate America raced to demonstrate social responsibility: boards hired chief diversity officers, pledged tens of billions toward DEI initiatives, and wove racial and gender targets into everything from supplier contracts to executive bonuses.
Goldman Sachs was no exception. The Company publicly declared that it is “committed to making progress toward racial equity, advancing gender equality, and increasing representation at every level of our firm.” It then set numerical hiring goals at the analyst and associate level for women, Black, and Hispanic employees. These goals are factored into executive pay through the annual cash incentives that are subjectively awarded by the Compensation Committee and, therefore, still drive executive behavior and business strategy. Any partial rollback of DEI policies rings hollow as long as these DEI goals remain in the compensation plan.
Goldman Sachs needs to get with the times. DEI is on the way out. The Supreme Court’s 2023 ruling in Students for Fair Admissions v. Harvard struck down race‑conscious admissions and kicked off a broader legal revolt against quota policies.
Although the case concerned higher education, the same reasoning is now being applied to the workplace, and litigation risk has exploded.
For example, Starbucks is now fighting a second high‑profile lawsuit alleging its DEI‑linked pay practices are discriminatory – coming on the heels of the $28.3 million judgment a former manager already won in 2023.
Since January, the Equal Employment Opportunity Commission has issued multiple advisories warning that incentives which “affect the terms, conditions, or privileges of employment” may violate Title VII. Just weeks ago, three law students even sued the EEOC itself for over‑collecting DEI data from major law firms – proof that regulators as well as companies are now targets.
Goldman Sachs is uniquely vulnerable. The firm has published explicit representation targets – including fifty‑percent women globally, eleven‑percent black analysts and associates in the Americas, and fourteen‑percent Hispanic analysts and associates. Further, the Company incentivizes executives to hit these targets by including them in the Compensation Committee’s vague “assessment framework.” Because the weighting is undisclosed, outside observers can only assume that hitting those numbers is essential to maximizing pay. That appearance alone is enough to invite shareholder suits, employee class actions, and EEOC investigations.
Every dollar diverted to defend quota‑driven policies is a dollar that cannot be deployed toward client service, technology, or risk management.
The reputational cost is even greater: clients choose Goldman because they believe it recruits on merit and its talent is known to be among the best in the world; any suspicion that identity politics trumps competence erodes that trust and pushes business to better‑governed rivals.
The solution is simple. Goldman Sachs should strip race and gender targets out of the incentive plan, and replace them with transparent, objective measures – such as risk‑adjusted returns, client‑satisfaction scores, and operational excellence. These are fully within management’s control and directly linked to long‑term value creation.
We do not oppose a diverse workplace achieved through equal‑opportunity recruiting. What we oppose are outcome‑based quotas, implemented for political purposes, that pressure managers to discriminate and that expose shareholders to staggering liabilities.
Goldman Sachs built its brand on rigorous risk management. Leaving quota metrics in the pay plan ignores today’s legal reality and risks damaging one of the most valuable brands on Wall Street, not to mention all of corporate America. By voting FOR Item 5 you will reinforce a culture of merit, and ensure that Goldman’s leadership is incentivized to deliver on performance, not politics.
Thank you.
Read NLPC’s shareholder proposal for the Goldman Sachs annual meeting here.
Read NLPC’s response, filed with the SEC, to the company’s opposition to our shareholder proposal, here.
(Pictured above: Goldman Sachs Chairman/CEO David Solomon)
