Goldman Sachs' DEI Employment Practices: What the Company's Own Documents Show — and What They Mean for Employees

Published August 22, 2026 · Last updated August 22, 2026 · By Fett Law — Michigan Employment Discrimination Attorneys

The Goldman Sachs Group, Inc. documented three categories of demographic employment practice in its own 2019–2023 reports: numeric race- and gender-based hiring and representation goals, career development programs whose participants were identified by race or sex, and recruiting pipelines defined by demographic category. Two of the four practices at the center of IBM's $17 million False Claims Act settlement with the U.S. Department of Justice in April 2026 — demographic goals for business units, and programs whose eligibility was limited by race or sex — are documented in Goldman's own reports.

Key facts

Did Goldman Sachs set racial or gender representation goals?

The framework began with the 2019 Sustainability Report, which described a "comprehensive action plan with aspirational hiring goals" covering the population that supplies most of the firm's hiring:

"Casting a Wide Net: Goldman Sachs' management team works closely with the firm's Global Inclusion and Diversity Committee to increase diversity of our global workforce at all levels of seniority. This includes a comprehensive action plan with aspirational hiring goals for analysts and associates hired on campus or laterally, a group that accounts for more than 70 percent of the firm's annual hiring."— The Goldman Sachs Group, Inc., 2019 Sustainability Report, p. 34 (source)

The same page published the numbers: 50% women globally, 11% Black professionals in the Americas, 14% Hispanic/Latinx professionals in the Americas, and 9% Black professionals in the UK. The report separately recorded a commitment, as a signatory of the UK Women in Finance Charter, "to ensuring women represent at least 30 percent of UK senior talent (VP and above)."

In 2020 Goldman extended the goals from hiring into representation — that is, into who holds a given job band. Its 2021 People Strategy Report describes the expansion and what the firm understood it would require:

"In 2020, we expanded our aspirational goals to include a focus on increasing the diverse representation of our firmwide vice presidents. We set out to achieve 40% women vice presidents, 7% Black vice presidents in the Americas, 9% Hispanic/Latinx vice presidents in the Americas, and 7% Black vice presidents in the UK by 2025. We knew these would be ambitious and would require accountability and new and innovative approaches to recruiting and retaining talent."— The Goldman Sachs Group, Inc., People Strategy Report 2021 — "Delivering Excellence Together", p. 12 (source)

The 2022 People Strategy Report restated the full set, adding a target for hiring from Historically Black Colleges and Universities:

"We aim for women professionals to represent 40% of our vice presidents globally by 2025 and 30% of senior talent (vice presidents and above) in the UK by 2023, while also endeavoring for women employees to comprise 50% of all our employees globally over time. We aim for Black professionals to represent 7% of our vice president population in the Americas and in the UK, and for Hispanic/Latinx professionals to represent 9% of our vice president population in the Americas, both by 2025."— The Goldman Sachs Group, Inc., 2022 People Strategy Report — "People, Partnership & Impact", p. 16 (source)

"We aim to double the number of campus hires in the US recruited from Historically Black Colleges and Universities (HBCUs) by 2025 relative to 2020."— 2022 People Strategy Report, p. 16

Goldman tracked and published performance against these targets every year. The final published scorecard, in the 2023 People Strategy Report, sets the goals beside actual results:

Source: The Goldman Sachs Group, Inc., 2023 People Strategy Report — "People, Teamwork, and Excellence", p. 17, "Aspirational Goals Update 2023" (source).

In plain terms: for six years Goldman Sachs published percentages, by race and by sex, that it wanted to reach in specific job bands — and reported annually on the gap between those percentages and its actual hiring and promotion results. A published number does not by itself decide any individual case. What matters legally is whether the number changed a decision. Employees and applicants who competed for analyst, associate and vice-president roles during that window, and the managers and recruiters who filled them, are the people most likely to know how the gap between goal and actual was worked in practice.

Did Goldman Sachs run programs restricted by race or sex?

The clearest single list is in Goldman's first People Strategy Report, published in April 2021 for 2020. Each program is described by the firm in its own words:

"Through our Black Analyst and Associate Initiative, we seek to grow and develop Black professionals by investing in their career development, enhancing connectivity to managers and providing access to a senior leader within their division, who serves as a coach."— The Goldman Sachs Group, Inc., 2020 People Strategy Report, p. 16 (source)

"Our Vice President Career Investment Initiative is a five-month leadership program offered to Black and Hispanic/Latinx VPs in the Americas and Black VPs in EMEA. It enables mid-tenured, high-potential vice presidents to be more successful in their current roles and unlock their potential for future opportunities by enhancing their skillsets, expanding their relationships and providing career guidance from their managers and divisional sponsors."— 2020 People Strategy Report, p. 16

"Our Vice President Sponsorship Initiative strengthens participants' leadership development through a robust sponsorship model, offered for women VPs in Asia Pacific, women VPs and VPs with disabilities in India, and women, LGBTQ+, Asian and Black VPs in EMEA."— 2020 People Strategy Report, p. 16

The same page describes the "Hispanic/Latinx Analyst Initiative," which "supplements Hispanic/Latinx analysts' day-to-day experience by fostering early and ongoing communication with their managers, divisional leadership and peers," and "The Asian Talent Initiative," described as "an annual program that improves the pipeline of Asian senior leaders by developing Asian managing director candidates and focusing on talent discussions with senior leadership about their career trajectories at the firm."

The programs were still running, and still described the same way, in the last edition Goldman published:

"Black and Hispanic/Latinx Analyst and Associate Initiative: Provides Black (Americas and EMEA) and Hispanic/Latinx (Americas) analysts and associates access to coaching support through our trained and more senior leaders."— The Goldman Sachs Group, Inc., 2023 People Strategy Report, p. 13 (source)

"Vice President Sponsorship Initiative: This program provides a sponsorship model for women, Black, Hispanic/Latinx, Asian, and LGBTQ+ vice presidents."— 2023 People Strategy Report, p. 13

Goldman also published what one of these programs was worth to the people admitted to it. Describing the Women's Career Strategies Initiative — "a five-month career management program" that "provides networking opportunities for women associates across the firm, as well as workshops and senior leader roundtables" — the 2023 report states: "32% of current Goldman Sachs women partners were WCSI participants" (p. 13).

That figure is why eligibility matters. What the law examines in a program like this is the pairing of an eligibility line drawn on a protected trait with a concrete employment benefit — a senior-leader coach, a divisional sponsor, a place in the partner pipeline. An employee who was told a coaching or sponsorship program "wasn't for them," and the managers who administered these programs, may have first-hand knowledge of how admission actually worked. For balance: Goldman's reports do not publish the formal eligibility terms of every program named here, and the firm ran other development programs — the Vice President Leadership Acceleration Initiative and the Managing Director Leadership Acceleration Initiative among them — that its reports describe in performance terms rather than demographic ones.

Did Goldman Sachs recruit through demographically defined pipelines?

Goldman described the demographic definition of its early-career recruiting programs directly:

"In addition to our core recruiting activities targeting talent across the world, the firm hosts flagship programs that provide people with disabilities, LGBTQ+, women, veterans, ethnically diverse and social mobility candidates with an opportunity to meet our people, develop skills and learn about roles at the firm."— The Goldman Sachs Group, Inc., 2022 People Strategy Report, p. 7 (source)

The 2019 Sustainability Report used nearly identical language three years earlier, listing among the firm's key initiatives "Exploratory Programs, providing LGBT+, women, ethnically diverse and social mobility candidates with the opportunity to meet our people, learn more about roles at the firm, and develop job-seeking skills, including networking and interviewing" (p. 35).

The HBCU program carried an express eligibility rule and a stated path into the firm:

"Undergraduate first- and second-year students from 12 participating HBCUs are eligible to participate. … Participants receive an academic scholarship upon successful program completion and are encouraged to apply for a summer internship the following year."— The Goldman Sachs Group, Inc., 2022 People Strategy Report, p. 8, describing the Goldman Sachs Market Madness: HBCU Possibilities Program (source)

And the firm credited a sex-defined program with moving its trading numbers:

"Women's Trader Academy: Launched in EMEA in 2017, the academy has led to an increase in representation of women across trading roles at the firm. This program supports a strong pipeline of junior women through a combination of training, mentoring, immersive trading simulations, and an opportunity to engage with senior leaders."— The Goldman Sachs Group, Inc., 2023 People Strategy Report, p. 7 (source)

One distinction is worth stating plainly, because it separates Goldman from several of its peers. Goldman's published reports from 2019 through 2023 do not describe a rule requiring that interview slates for its own open roles include candidates of a particular race or sex. The "at least one diverse" requirement that Goldman announced in 2020 applied to clients: from July 1, 2020 the firm committed to taking companies public in the U.S. and Western Europe only if they had at least one diverse board member, raised to two from July 2021 (2020 Sustainability Report, p. 33). That is a client-underwriting policy, not an employment practice, and Goldman dropped it in February 2025. Whether any internal slate guidance existed is not answered by the public record.

Did Goldman Sachs tie executive pay to diversity targets?

Goldman's 2024 proxy statement describes the Compensation Committee's mandate in these terms:

"Assist our Board in its oversight of the development, implementation and effectiveness of our policies and strategies relating to our human capital management function, including: recruiting, retention and career development and progression; management succession …; and diversity and employment practices."— The Goldman Sachs Group, Inc., Proxy Statement for the 2024 Annual Meeting of Shareholders (source)

The People Strategy Reports approach compensation from the pay-equity side rather than the incentive side. The 2022 edition states that Goldman is "committed to compensating our employees fairly and equitably and to promoting gender and racial/ethnic diversity and inclusion in our leadership ranks and broader workforce," and that "our hiring, promotion and compensation practices and policies are designed to support equitable treatment" (2022 People Strategy Report, p. 25).

This matters for two reasons, in opposite directions. It is a genuine difference from the IBM settlement, in which the Justice Department alleged a "diversity modifier" tying bonus compensation to demographic targets — a mechanism Goldman's public documents do not describe. It is also a limit on what the public record can tell anyone: incentive-compensation mechanics, divisional scorecards and internal goal-setting instructions are ordinarily internal documents. Employees who sat in those conversations know things the reports do not say.

How Goldman Sachs' DEI program changed, 2019–2026

Why these practices matter legally

Two recent Supreme Court decisions sharpened the rule. In Muldrow v. City of St. Louis (2024), the Court held that a plaintiff challenging a discriminatory job transfer need show only some harm from the change in the terms or conditions of employment, not a "significant" disadvantage. In Ames v. Ohio Department of Youth Services (2025), the Court unanimously rejected the rule — applied in several circuits — that majority-group plaintiffs must produce additional "background circumstances" evidence that a defendant is the unusual employer who discriminates against the majority. Separately, 42 U.S.C. § 1981 prohibits race discrimination in the making and enforcement of contracts — including employment relationships — and carries a four-year window with no agency filing requirement. (Title VII, 42 U.S.C. § 2000e-2.)

For companies that do business with the federal government, a second layer arrived on April 10, 2026, when International Business Machines Corporation paid $17,077,043 to resolve allegations — under the Justice Department's Civil Rights Fraud Initiative, in DOJ's first False Claims Act settlement of its kind — that it certified compliance with federal anti-discrimination requirements while operating DEI practices including a diversity modifier tying bonus compensation to demographic targets, "diverse interview slates," race and sex demographic goals for business units, and training, mentoring and leadership programs whose eligibility was "limited on the basis of race or sex" (DOJ press release). Two of those four categories — demographic goals for business units, and programs limited by race or sex — track what Goldman Sachs documented in its own reports. The first, a compensation modifier, does not appear in Goldman's public filings. Our guide to illegal DEI practices sets out all four categories and the other major employers whose own documents describe them. On the government-business side, Goldman Sachs & Co. LLC is a designated primary dealer of the Federal Reserve Bank of New York, and Goldman Sachs Asset Management has held published investment management agreements with the New York Fed; whether any Goldman entity was a covered federal contractor making the certifications at issue in a given period is a fact-specific question that the public record does not settle.

To be clear about what is and is not established: no court or agency has found that Goldman Sachs' practices violated any law, and the IBM settlement itself resolved allegations without any admission or determination of liability. But practices like those documented above — published numeric race- and sex-based targets for specific job bands, and career development programs whose participants were identified by race or sex — are precisely the categories that can give rise to liability under Title VII and § 1981, and, for companies doing business with the federal government, potential False Claims Act exposure.

Were you affected by these practices at Goldman Sachs?

If you worked at The Goldman Sachs Group, Inc. — or applied there — between 2019 and 2025, the documented practices above may have touched your career in ways worth examining:

• You were passed over for an analyst, associate or vice-president role — or for promotion into one — during a period when Goldman was publishing, and reporting annually against, numeric race- and sex-based targets for that exact job band.
• You were excluded from a coaching or sponsorship program — the Vice President Sponsorship Initiative, the Vice President Career Investment Initiative, the Black or Hispanic/Latinx Analyst and Associate Initiatives, the Women's Career Strategies Initiative — or were told one was not for you, because of your race or sex.
• You were steered away from, or never told about, a recruiting program whose participants Goldman defined by demographic category.
• You were a manager, recruiter, or human capital professional with first-hand knowledge of how the aspirational goals were translated into instructions about particular openings, promotion rounds, or program admissions.

There is a separate question worth asking if your work touched a Goldman entity's dealings with a federal agency. The False Claims Act's qui tam mechanism lets an individual bring a claim on the government's behalf, and potentially share in any recovery, where a company certified compliance with federal anti-discrimination requirements while doing something else — the theory the Justice Department used against IBM. Whether any Goldman Sachs entity made certifications of that kind during the relevant period is a fact-specific question the public record does not answer; it is the sort of thing an insider may know. Qui tam complaints are filed under seal, so a whistleblower's identity is initially protected. Both Title VII and the False Claims Act prohibit retaliation against people who assert their rights or report violations.

If any of these fits, it costs nothing to find out where you stand — meet our DEI discrimination lawyers, or start below.

What could a claim against Goldman Sachs be worth?

Whistleblower rewards under the False Claims Act

Under 31 U.S.C. § 3730(d), a qui tam whistleblower (called a "relator") is entitled to 15–25% of what the government recovers when the Justice Department intervenes, and 25–30% when the relator litigates without government intervention. For scale: on a settlement the size of IBM's $17,077,043, the intervened-case whistleblower share would be roughly $2.6 million to $4.3 million. Because False Claims Act recoveries are built on treble damages plus per-claim penalties, recoveries against very large government counterparties can run substantially higher.

Damages in individual discrimination cases

Back pay and front pay are uncapped under Title VII. Compensatory and punitive damages under Title VII are capped by employer size — $300,000 for employers with more than 500 employees, the bracket Goldman Sachs occupies — but race claims under 42 U.S.C. § 1981 carry no damages caps at all, which is one reason race discrimination cases are often pleaded under it, and many state civil-rights statutes (including Michigan's Elliott-Larsen Civil Rights Act and the New York State Human Rights Law) are likewise uncapped. Prevailing plaintiffs generally recover attorney's fees on top. For a sense of what employment discrimination cases can produce, Fett Law's own results include a $10.5 million race and age discrimination class action against Ford Motor Company, a $2 million disability harassment result, and a $1.6 million racial harassment result. Prior results do not guarantee a similar outcome.

Class action potential

Class actions are built on a single policy applied to many people — and the practices documented above are firmwide by design: one set of published goals covering analyst, associate and vice-president populations across the Americas and the UK, and one set of development programs administered centrally. Goldman Sachs has already resolved one employment class action of this scale: the $215 million Chen-Oster settlement in 2023, on behalf of roughly 2,800 women associates and vice presidents, resolved allegations Goldman denied. Historic employment-discrimination class settlements show the broader range such cases can reach: Coca-Cola paid $192.5 million (2000), Texaco $176.1 million (1996), and Novartis $175 million (2010) to resolve class claims.

Every case depends on its own facts — these figures show the range the law makes possible, not a promise of any outcome. The fastest way to learn where your situation falls is to start a confidential intake or request a free consultation.

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