Goldman Sachs Code of Business Conduct mandates affirmation, permits termination

Goldman Sachs requires every employee to affirm that they have reviewed and will comply with its Code of Business Conduct and Ethics, and the firm says it will impose disciplinary measures up to and including firing for violations. The firm’s language makes clear that breaches can also “constitute violations of law, which may result in criminal or civil penalties for individual employees and/or the firm.”

The Code is described internally as the firm’s core employee policy covering areas such as personal conduct, conflicts of interest, insider trading and material non‑public information, anti‑bribery and anti‑corruption, and recordkeeping. Goldman Sachs operates several distinct codes for different audiences: a firmwide employee Code; a Goldman Sachs BDC, Inc. Code of Business Conduct and Ethics adopted November 11, 2014; a GS Acquisition Holdings Corp II Code of Ethics and Business Conduct (document identifier 854030.01E-LACSR01A - MSW); and a Vendor Code of Conduct published January 2022 for third‑party suppliers and subcontractors.

The BDC code ties the firm’s obligations to regulators, stating in part, “Pursuant to Section 406 of the Sarbanes-Oxley Act of 2002, the Securities and Exchange Commission (the ‘SEC’) has adopted rules requiring annual disclosure of an investment company’s code of ethics applicable to its principal executive, principal financial and principal accounting officers (the ‘Covered Officers’). Pursuant to Section 303A.10 of the NYSE Listed Company Manual, the New York Stock Exchange, LLC (the ‘NYSE’) requires that a listed company adopt and disclose a code of business conduct and ethics for directors, officers and employees (collectively with the Covered Officers, the ‘Covered Persons’).”

Governance and reporting channels are emphasized across the documents. The Board of Directors and management pledge oversight and accountability, and the GS Acquisition Holdings code says the Board “will investigate any reported violations and will oversee an appropriate response, including corrective action and preventative measures.” Employees are instructed that “Regardless of whether you choose to address such behavior directly, you are required to promptly escalate potential discrimination and harassment concerns to Employee Relations or through the Business Integrity hotline.” The firm also states plainly, “All of our employees are required to affirm that they have reviewed this Code and will comply with it.”

Third‑party obligations are spelled out in the Vendor Code, which asks suppliers to align policies across their organizations and supply chains and lists explicit management standards: “Examples of management systems with a scope related to the content of this Code include: ISO 9001, ISO 14001, ISO 50001, SA8000, OHSAS 18001 and ISO22301.” Vendors must report any facts or circumstances likely to impair compliance to their Goldman Sachs relationship manager.

For employees, the practical effects are immediate: mandatory affirmation, formal escalation channels, and a clear enforcement posture that includes termination and possible legal exposure. The firm’s Business Principle captures the stakes: “Our assets are our people, capital and reputation. If any of these is ever diminished, the last is the most difficult to restore.”

Several passages in the excerpts provided are truncated, including portions of the non‑retaliation language and some disciplinary specifics, so workers and compliance officers should review the full published texts or ask Employee Relations or Compliance for the complete Code language. Expect continued emphasis on affirmations, internal reporting and board oversight as Goldman Sachs applies these standards across employees and external partners.