4. 5. 6. It provides a logical way to assess the causation of climate change, which is a global problem on a global scale caused by greenhouse gas emissions from a wide number of actors over a long period of time; It is generally only at the level of the parent company where top line strategic decisions regarding the emissions intensity of products, capital allocation and the mix of energy sources in a company's portfolio can be made; and Most of the respondent companies named in Annex C to the Petition report (either voluntarily or under national regulation) their greenhouse gas emissions on a group-wide basis, consistent with the practice of consolidating the company's financial accounts (and in accordance with the Greenhouse Gas Protocol). 307 It is therefore appropriate to impute control over the emissions of subsidiaries, and their consequent climatic impacts, to the parent company. 308 C. In applying the UNGPs, the Commission should pay particular regard to Principles 11-17 and Principle 22 The UNGPs provide that enterprises have responsibilities to respect human rights in all of their operations, and set forth both foundational and operational principles for the fulfillment of these responsibilities. For purposes of the present inquiry, Amici ClientEarth, CIEL, Plan B, and APF-GANHRI call the Commission’s attention to the principles below, and offer specific recommendations in the application of these principles.    Principle 11 - Businesses “should respect human rights” by “avoid[ing] infringing on the human rights of others and” addressing any “adverse human rights impacts with which they are involved.” Principle 11 should be read as imposing a responsibility over and above compliance with national laws and regulations, such as those governing the permitting of industrial facilities (in accordance with the commentary accompanying the Principle).309 The Commission may offer insights and recommendations regarding what may constitute “adequate measures” for the prevention of the human rights impacts of climate change, as required by principle 11.310 Principle 12 - Rights that must be respected by all businesses include, at minimum, the rights recognized in the International Bill of Rights (UDHR, ICCPR, ICESCR) and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. Principle 13 – “The responsibility to respect human rights requires that business enterprises: o avoid causing or contributing to adverse human rights impacts through their own activities, and address such impacts when they occur; and 307 The Greenhouse Gas Protocol is the international standard by which most companies calculate and report on greenhouse gas emissions from their operations and products. The Protocol divides emissions into three categories, scope 1, being direct emissions from activities; scope 2, being emissions from electricity used by corporate operations; and scope 3, being the full emissions of the company's products throughout their life-cycle. For more details see the Greenhouse Gas Protocol, http://www.ghgprotocol.org/. 308 ClientEarth brief, at ¶¶ 98-100. 309 Id. at ¶ 108. 310 Id. at ¶ 108. 63