4 • The oil industry was expressly warned of the potential severity of climate risks by its own consulting scientists in 1968 and repeatedly thereafter. • Numerous industry documents demonstrate these risks were communicated by industry scientists to executives at the highest levels of the industry over the ensuing decades. • The oil industry held early patents on numerous technologies that might have reduced climate change risk. • Even while blocking public action to address climate change, oil companies took steps to protect their own assets from climate risks. This divergence between industry communications to the public and industry action to safeguard their own investments began as early as the 1970s and is well established by the 1980s. • Notwithstanding their own best information, leading oil companies and industry associations actively participated in or funded climate misinformation efforts for decades through media intended to reach wide audiences of consumers, investors, and the general public. In the nine months since the Smoke and Fumes synthesis report was released, these findings have been extended and buttressed through additional research by CIEL and others, including through the report A Crack in the Shell, which is discussed more fully herein. Q8: A8: Q9: A9: Are you familiar with the Petition filed by Greenpeace, along with thirteen (13) non-profit organizations and eighteen (18) individuals, before the Philippine Commission on Human Rights requesting for an investigation of the Carbon Majors for human rights violations or threats thereof resulting from the impacts of climate change? Yes. How did you become familiar with said Petition? CIEL was one of several expert organizations approached to provide advice and support to the petitioners in conjunction with the filing of the original petition in 2015. CIEL submitted an opinion and annex in support of the Petitioners in February 2017. CIEL also collaborated with other amici expert organizations in the submission of a Joint Summary of the Amicus Curiae briefs, which summarizes the key findings of messages of the individual submissions. Q10: Given your background and extensive experience in climate, energy, human rights, and civil litigation matters as mentioned in your brief bio and Curriculum Vitae (Annex “A” hereof), what can you say about the Petition, if any? A10: The Commission’s inquiry is of critical importance first and foremost to the people of the Philippines, who have suffered devastating impacts from anthropogenic climate change and who will continue to suffer new impacts for decades or centuries to come. Those whose lives have been affected most directly and most acutely by climate change have both an urgent need and a fundamental right to access to information and access to justice. That right

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