Amicus Curiae Brief presented by ClientEarth 21 November 2016 has an historic opportunity to advance international norms regarding human rights, by issuing findings in relation to the factual causal link between the past and current greenhouse gas emissions of the corporations listed in the Petition and the human rights impacts arising from the effects of climate change. As the International Coordinating Committee of National Institutions for the Promotion and Protection of Human Rights states: "[t]hrough their role in promoting and protecting human rights, national human rights institutions can play an important part in engaging with business and human rights issues to ensure that States, businesses and civil society uphold their respective duties and responsibilities with regard to business interaction with human rights."8 12. This brief first addresses the jurisdictional issues that the Commission must consider. It then outlines the international legal framework governing climate change and human rights, which provides the context for the Commission's investigation, including the implications of the historic Paris Agreement. Next, it considers several issues relevant to the Commission's fact finding investigation and the elements of factual causation in the context of climate change. 13. Finally, ClientEarth makes submissions regarding the appropriate recommendations that the Commission may choose to make, in respect of both the obligations of the State of the Philippines and the responsibilities of the Carbon Majors, as follows: 8 International Co-ordinating Committee of National Human Rights Institutions for the Promotion and Protection of Human Rights, Business and Human Right: a Guidebook for National Human Rights Institutions, (Nov 2013) Available at http://www.humanrights.dk/files/media/dokumenter/udgivelser/bhr_guidebook_for_nhris_2013_eng.pdf 7