109 iv. Concretize the Responsibility of Businesses in the Context of Climate Change According to the United Nations Office of the High Commissioner for Human Rights, “States should be accountable to rights-holders for their contributions to climate change including for failure to adequately regulate the emissions of businesses under their jurisdiction regardless of where such emissions or their harms actually occur.”501 National and subnational governments that have authority to regulate the exploration, growth, and operation of natural resources or industrial enterprises, as well as State agencies that have authority to regulate environmental or human rights protection within their jurisdiction, must require companies to prepare decarbonizing analysis, planning and commitments, including corporate actions to carry out said plans and the legal duty of directors and officer relating to such.502 To help fulfill their duty to protect human rights, States should “encourage, and where appropriate require, business enterprises to communicate how they address their human rights impacts,”503 especially when their business operations impact human rights. While corporations are already mandated to submit financial reports to government regulators, States should further require the submission of non-financial reports relating to environmental and climate change impact assessments, disclosure of human rights due diligence and consideration of human rights risks, consistent with the Guiding Principles. Necessarily, States should strictly monitor such submissions and impose appropriate penalties for non-compliance. Importantly, these reports should be accessible to investors and the general public. 501 Id. at 3, para. 3. 502 David Estrin & Cynthia A. Williams, Unique Legal Obligations of Officers and Directors of Carbon Major Enterprises and their Investors to Reduce Enterprise Carbon Emissions and Avoid Climate Change Related Human Rights Impacts to Vulnerable Communities, and Measures these Enterprises and their Directors should Implement to Act on/Comply with these Obligations: Summary of Recommended Measures to Reduce and Potentially Avoid Human Rights Impacts in the Planning, Financing and Approval of New or Expanded Carbon Plans and Projects (2018), available at https://ccli.ouce.ox.ac.uk/wp-content/uploads/2018/10/Recommendations-for-the-Philippines-CHR. pdf. 503 UNGP-BHR, supra note 313 (Principle 3 d).