Memorandum for the Petitioners 1151 g) From the entry into force of the Kyoto Protocol to the adoption of the Paris Agreement, the fossil fuel industry’s attack on climate science and solutions continued unabated;702 h) Following the adoption of the Paris Agreement in 2015 and the publication of the IPCC’s SR 1.5°C in 2018, the corporate action continued to demonstrate an intent to put profit over people;703 and i) Even today, the respondent Carbon Majors’ business models, investments, and activities are inconsist with climate science and purported commitments to human rights and climate change.704 A.5. Findings concerning the obligations of the Philippine Government r r a) The Philippine government has an obligation to respect, protect, and fulfill human rights, including the right to a healthful and balanced ecology and a safe climate. Human rights norms provide a framework for understanding how States should respond to climate change in order to meet their legal obligations;705 b) States’ obligations to address environmental harm that interferes with the full enjoyment of human rights extends to harm caused by the impacts of climate change;706 c) The Philippine government is obligated to contribute to efforts, to the best of its ability, to keep global average temperatures to a level that avoids dangerous anthropogenic interference with the climate system, as evidenced by the best available science;707 d) Human rights law imposes wide-ranging obligations upon States to protect the human rights of individuals from infringements by third parties, including corporations;708 e) States have an obligation to respect , protect, and fulfill human rights, and this obligation includes actively Part V (D), pp. 59-62 Part V (D), pp. 62-63 704 Part V (D), pp. 63-65; Also see Annexes “D” and “E” hereof. 705 APF Sc GANHRI, CIEL, ClientEarth , EL AW, Maastricht Principles Drafting Group, Our Children’s Trust, Plan B, Joint Summaiy of the Amicus Curiae, supra note 50, p. 10. 706 Ibid. 707 Ibid' p. 53. 708 Ibid. p. 50. 702 703

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