16 2.27. In any event, the respondents’ complex corporate structure does not prevent the Honorable Commission from conducting a thorough investigation with the aim to prevent further human rights harms going forward. In accordance with international norms and standards, all businesses enterprises, “regardless of their size, sector, location, ownership and structure,” have the responsibility to respect human rights.47 2.28. Further, the Honorable Commission’s investigation requires consideration of the entirety of respondents’ activities, including the activities of Carbon Major parent entities and subsidiaries. For purpose of this human rights investigation, the enterprise theory of corporate personhood is useful in assessing the activities of a corporate group as a unit, as opposed to the activities of parent entities and subsidiaries as separate legal entities.48 The theory is a response to the formalistic approach which “ignores the economic reality of the relationship between parent corporations and their subsidiaries.”49 The relationships formed by corporate groups are often “an interconnected web of corporations that function toward a unified goal.”50 2.29. The OECD Guidelines for Multinational Enterprises, a comprehensive code of responsible business conduct that was multilaterally agreed and governments are committed to promoting,51 support the application of the enterprise theory. The 2011 update to the Guidelines explicitly state that the OECD principles “extend to enterprise groups” and “compliance and control systems should extend where possible to these subsidiaries.”52 2.30. For the purpose of this investigation, the Honorable Commission may adopt an approach that will allow it to assess the global activities of the respondents, which currently have a central purpose of producing and selling fossil fuels for profit, and the cumulative impact of these activities on the Philippines. With climate change matters, the parent company, unless otherwise stated by the respondents, sets “top line strategic decisions regarding emissions intensity of products, capital allocation and 47 Guiding Principles, principle 14, available at http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf, last accessed on 06 February 2017 [hereinafter Guiding Principles]. 48 Dearborn, M. (2009). Enterprise Liability: Reviewing and Revitalizing Liability for Corporate Groups, California Law Review, Vol. 97, Issue I, p. 210, available at http://scholarship.law.berkeley.edu/cgi/viewcontent.cgi?article=1152&context=californialawreview (citing Gower, L.C.B. The Principles of Modern Company Law, p. 213 K.W. Wedderburn & 0. Weaver eds. 3d ed. 1969), last accessed on 06 February 2017. 49 Id., p. 209 (citing Adolf A. Berle, Jr., The Theory of Enterprise Entity, 47 COLUM. L. REV. 343) 343 [1947]) 50 Id. 51 OECD 2011 Guidelines for Multinational Enterprises (2011), p. 3, available at https://www.oecd.org/corporate/mne/48004323.pdf, last accessed on 06 February 2017. 52 supra., note 51, p. 19, 22.