Amicus Curiae Brief presented by ClientEarth 21 November 2016  a business that targets high sugar foods at children, contributing to childhood obesity. 91. These examples demonstrate the potential scope of the Guiding Principles, and confirm that a business may contribute to a human rights impact through the legal sale of its products. These examples are analagous to the situation of the Carbon Majors, many of whom legally sell fossil fuels and other products for energy use. Despite the fact that their products are accepted and used on a wide scale, their human rights impacts must also be acknowledged by the Carbon Majors. 92. ClientEarth does not suggest that all business enterprises, including small and medium enterprises around the world, should be held to the same standards in the context of the human rights implications of climate change, as should the Carbon Majors.71 This is because the Carbon Majors, as demonstrated by the evidence of Heede provided by the Petitioners, have, through their operations and products, contributed to the emission of such significant quantities of greenhouse gas emissions into the earth's atmosphere so as to impose upon them specific and particular obligations in respect of climate change. This interpretation is consistent with the approach taken in the Guiding Principles, particularly Principle 14. The application of the Principle is discussed in further detail in section 7.4. 93. ClientEarth agrees with the Petitioner's assertion that the Interpretive Guidance issued by the OHCHR may be relied upon by the Commission in deciding the appropriate test for determining whether the activities of the Carbon Majors have 71 This is recognised in Principle 14, which states that "the means by which a business enterprise meets its responsibility to respect human rights will be proportional to...its size". 45

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