2 International Norms and Standards3 in the third public hearing of the case on 2930 August 2018 at the Commission on Human Rights in Quezon City, Philippines. This Statement confirms and builds on the presentation and documents Carroll prepared for the second public hearing last 23 May 2018. Carroll will also explain the findings in a new CIEL briefing, “A Crack in the Shell: New Documents Expose a Hidden Climate History,”4 published in April 2018. Carroll agreed to be a witness and resource person for the petitioners and answer in writing questions to be asked of him. On 12 July 2018, one of the legal representatives for the petitioners, Attorney Hasminah Paudac, talked with Carroll via Skype and explained to him the process of statement-taking. Attorney Kristin Casper, Greenpeace Canada’s litigation counsel and international legal coordinator, and Carroll’s colleagues from CIEL were also in that call. On 13 July 2018, Ms. Anna Dominique Esmeralda, legal liaison of the petitioners, sent questions to Carroll, which he personally answered. Carroll submits this Statement, along with his Curriculum Vitae and PowerPoint presentation, to the Commission on Human Rights. He commits to elaborate and clarify this in the scheduled public hearing. Questions and Answers Q1: A1: Can you please give us a background about your organization, the Center for International Environmental Law (CIEL)? Center for International Environmental Law (CIEL) is a not-for-profit, charitable legal organization that uses the power of law to protect the environment, promote human rights and ensure a just and sustainable society. From offices in Washington, DC, and Geneva, Switzerland, CIEL’s team of lawyers, experts and support staff works to address an array of issues affecting human health, human rights and the environment. CIEL has been active in efforts to address the threat of climate change since the organization’s founding in 1989. Q2: A2: How long have you been with CIEL? I have been with CIEL in my current role since September 2010. Previously, I served with CIEL as a legal intern from June through August 1996 and as a law fellow from June 1997 through January 1998. Q3: From CIEL’s website, it appears that you are the President and Chief Executive Officer. How long have you held said position? I have been with CIEL for approximately eight years. A3: Q4: A4: As President and CEO of CIEL, what are your key roles and responsibilities? I am responsible for the leadership and oversight of all aspects of CIEL’s programmatic work and operations, including strategic direction, legal A copy of which was attached to petitioners’ Consolidated Reply dated 10 February 2017 and marked as Exhibit “G” during the preliminary conference held on 11 December 2017. This is also available at: http://www.ciel.org/reports/smoke-and-fumes/, last accessed on 13 July 2018. 4 Available at https://www.ciel.org/wp-content/uploads/2018/04/A-Crack-in-the-Shell_April2018.pdf; last accessed on 13 July 2018. 3

Select target paragraph3