involving meaningful consultation with potentially affected groups and other relevant stakeholders (Principle 18); d) Take appropriate action to mitigate the greenhouse gas emissions from their operations and products, which may (or may not) constitute a crucial relationship as defined in Principle 19, for some of the Carbon Majors; and e) Track the effectiveness of their response by fully and adequately reporting on their total greenhouse gas emissions (including across the full life-cycle of their products), as well as proposed actions to mitigate their emissions into the future including appropriate emissions reduction targets, and diversification of energy sources. This should be transparently produced and documented, in order to fully comply with Principles 20-21. The UNGPs are intended “to prevent business enterprises from escaping responsibility through the outsourcing of potentially harmful activities to others through their business relationships.”314 Therefore, the scope of due diligence includes addressing adverse human rights impacts that the business may cause or contribute to through its own activities, or which may be directly linked to its operations, products, or services by its business relationships. This includes being held accountable for climate impacts.315 D. The UNGPs should be interpreted in light of and in accordance with international environmental law and the international law governing climate change In this investigation, compliance with the UNGPs should be interpreted by the Commission in light of, and in accordance with, international law governing climate change, including the UNFCCC, and other norms of international environmental law, including the precautionary principle and the polluter pays principle. First adopted more than a quarter century ago, the UNFCCC has been ratified by 197 Parties, representing near universal adherence by the global community. The ultimate objective of the UNFCCC, as set forth in Article 2, “is to achieve...stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system.”316 In 2015, the UNFCCC Parties adopted the Paris Agreement to enhance implementation of the Convention, including its ultimate objective. To this end, the 175 Parties to the Paris Agreement have agreed to hold the global average temperature increase to well below 2 degrees Celsius and to pursue efforts to limit warming to no more than 1.5 degrees Celsius.317 The Paris Agreement further calls on Parties to respect, promote, and consider their human rights obligations when taking actions to address climate change. Significantly for purposes of the present inquiry, the OHCHR has affirmed that businesses, as human rights duty bearers, “must be accountable for their climate impacts and 314 See Mark B. Taylor (ICAR), Human Rights Due Diligence: The Role of the States 13 (2013 Update), available at www.bhrinlaw.org/icar-human-rights-due-diligence-2013-update-final.pdf. 315 See UNDERSTANDING HUMAN RIGHTS AND CLIMATE CHANGE, supra note 57. 316 UNFCCC, supra note 279, at art. 2. 317 The number of Parties who have ratified the Paris Agreement is based on the number who have ratified on the date of filing of this joint summary amicus brief. Paris Agreement - Status of Ratification, http://unfccc.int/paris_agreement/items/9444.php (last visited on Mar. 18, 2018). 65