WILMINGTON, Delaware (Reuters) - A shareholder sued Goldman Sachs Group Inc's board for excessive bonuses and wants bank executives to pay the $500 million in charitable donations that Goldman is making after being criticised for its compensation policy.

Goldman Sachs bonuses substantially exceed what competitors pay "even though, on a risk-adjusted basis, Goldman's officers and managers have performed over the past several years in a manner that is, at best, only average," the lawsuit says.

The Southeastern Pennsylvania Transportation Authority (SEPTA), which runs public transit in the Philadelphia area, filed the lawsuit on Wednesday in Delaware's Chancery Court.

SEPTA said Goldman has been allocating nearly half of its revenues to staff bonuses even though the company's performance has been less a benefit of management skill than risks it has taken with investors capital.

"Goldman's employees are unreasonably overpaid for the management functions that they undertake, and shareholders are vastly underpaid for the risks taken with their equity," it said.

The lawsuit is entirely without merit, a Goldman spokesman said.

Goldman Sachs released its earnings report yesterday and dramatically changed course on pay by setting aside nothing for compensation in the fourth quarter. That helped the company report better earnings than analysts had forecast.

The company said it would give $500 million to charity, in part to improve its public image.

Members of Congress have proposed taxing bonuses paid by banks that received government bailout money, which includes Goldman Sachs. SEPTA's suit demanded such a tax be paid by Goldman Sachs managers, not shareholders.