Amicus Curiae Brief presented by ClientEarth 21 November 2016 97. This intent is also able to be ascertained by the fact that the Petition refers to the Guiding Principles as the primary document containing the international norms and standards applicable to corporate activity in respect of human rights. The Guiding Principles apply to nation-states and "all business enterprises, both transnational and others, regardless of their size, sector, location, ownership and structure". They also state that "the responsibility to respect human rights applies fully and equally to all business enterprises," whether that operation conducts business through a corporate group or individually.75 98. Second, for the purposes of this fact finding investigation, the Commission should adopt an enterprise theory of corporate personhood, meaning that the activities of the whole group of companies (and specifically the greenhouse gas emissions of the group as a whole) should be aggregated and attributed to the parent entity. This approach should be adopted because: a. it is the only practical way to assess the activities of multinational corporations whose operations and products produce greenhouse gas emissions across multiple jurisdictions, and reflects the manner in which these organisations in fact operate; b. this is the accepted approach in the context of human rights violations resulting from the activity of multinational entities, and is adopted by the 75 OCHCR, UN Guiding Principles on Business and Human Rights, 2014. 47