Memorandum for the Petitioners | 138 International human rights law and other international agreements on 8.196. To avoid needless redundancy, petitioners adopt their discussion corporate responsibility under different international treatises and agreements, as discussed in their Petition and Consolidated Reply. Considering that this is an investigation on the responsibility of the respondent Carbon Majors in the context of climate change using the human rights lens, petitioners digested below pertinent discussion under international human rights law. 8.197.States have the obligation to mitigate the harmful effects of climate change by taking all reasonable steps to the full extent of their abilities to prevent or reduce greenhouse emissions within the shortest possible time, both nationally and through international cooperation, and to hold the increase in temperature below levels that would cause widespread harm to the enjoyment of human rights.“ They must adopt all necessary measures to assist those within their jurisdiction to adapt to the foreseeable and unavoidable effects of climate change, thereby minimizing the impact of climate change on their human rights. &” 8.198.Human-rights based climate action should be transparent and accountable, sustainable, evidence-based, and non-discriminatory in nature, ensuring the access and participation of vulnerable groups.®* The obligations of States to respect, protect, and fulfill human rights is enshrined in numerous treaties, as well as part of the international customary law and national law. It is also at the cornerstone of the first pillar of the UNGPs.*” 8.199. All States have these obligations regardless of whether they are directly responsible for the human rights violations in question, since all States have an obligation to protect human rights from harms caused by third parties, including businesses.°° 8.200. A State may also be responsible for extraterritorial human rights violations where there is a causal connection between an activity in its territory (or jurisdiction) and transboundary environmental harm that impairs This was one of the human rights in another territory or jurisdiction. conclusions by the court in the Advisory Opinion on the Environment and Human Rights and the Environment, published by the Inter-American Court 646 Knox, J., TSN dated 27-28 September 2018, p. 110, supra note 511. 647 Naidoo, K., supra note 628, p. 9. 648 See Exhibit “NNNNNNNNN” December 2018, p. 2. 9 Id p. 1. to “NNNNNNNNN-1,” Statement of Ms. Loretta Ann Rosales, dated 11 650 Naidoo, K., TSN dated 11-12 December 2018, p. 120, supra note 374.