Memorandum for the Petitioners |129 are linked to the harms arising from climate change.®° Principle 13 of the UNGPs states: The responsibility to respect that business enterprises: human rights More specifically, requires a) Avoid causing or contributing to adverse human rights impacts through their own activities, and address such impacts when they occur; b) Seek to prevent or mitigate adverse human rights impacts that are directly linked to their operations, products or services by their business relationships, even if they have not contributed to those impacts.5° 8.166. Principle 13 of the UNGPs is utilized when business activities contribute to adverse human rights impacts, even though it may not be the only cause of the adverse impact. The UNGPs call for the application of a of a standard by balanced causation, contributory of test reasonableness.°” 8.167. Principle 19(b) of UNGPs further elaborates on appropriate action, which will vary according to “(i) whether the business enterprise causes or contributes to an adverse impact, or whether it is involved solely because the impact is directly linked to its operations, products or services by a business relationship; (ii) the extent of its leverage in addressing the adverse impact.” 8.168. In the climate change context, respecting the UNGPs means that business enterprises, including the respondent Carbon Majors should stop causing or contributing to adverse human rights impacts through their own activities -- such as the production, marketing, and sale of fossil fuels and efforts to delay or stop regulations restricting fossil fuels. They must also address such climate-related human impacts when they occur, as well as prevent or mitigate adverse climate-related human rights impacts that are directly linked to their operations, products or services by their business relationships, even if -- assuming for the sake of argument -- they have not contributed to those impacts. 8.169. Principle 13 of UNGPs also requires that business enterprises use appropriate means equivalent to the scale of the risks to human rights from climate change to reduce their emissions in order to meet their responsibility to respect human rights. 605 606 697 68 Addo, M., supra note 590, p. 5. UNGPs, supra note 583. ClientEarth Amicus Brief, supra note 37, para. 90; Also Interpretive Guide, supra note 589. Principle 19 UNGP, supra note 583. 69 Principle 12 UNGP, supra note 583; Joint Summary of the Amicus Curiae, supra note 50, p. 64.