Memorandum for the Petitioners | 66 5.128.Based on petitioners’ expert submissions summarized in Annexes “D” and “E,” there is no evidence that respondent Carbon Majors have adequately and transparently taken the following actions to-date: a) Align their business models to a global average temperature level that avoids or minimizes dangerous anthropogenic interference with the climate system as evidenced by the best available science and, at the very minimum, with the politically agreed 1.5°C temperature goal in the Paris Agreement and a carbon budget that provides the greatest possibility of keeping warming below 1.5°C; b) Take responsibility for the actual, real emissions from its products and operations, and not the company’s “net carbon footprint”;?”” c) Adequately acknowledge the impacts of climate change on the exercise of human rights since they first became aware of the potential climate risks and into the future;?” d) e) f) Renounce policy;?” disinformation on climate science and Include climate change as a human rights matter in human rights due diligence;?*° Identify and assess the specific human rights impacts of climate change arising from their operations and products, drawing on human rights expertise, and involving meaningful consultation with potentially affected groups and other relevant stakeholders in the Philippines;2®! and g) Track the effectiveness of their response by fully reporting on their total GHGs (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 investments into renewable energy). 78? 277 See e.g. Muttitt, G. (20 May 2019), Shell’s Emissions Still Going Up Despite Accounting Device, available at http://priceofoil.org/2019/05/20/shell-emissions-still-going-up-despite-accounting-trick/ (last accessed on 12 September 2019). 2%8 Joint Summary of the Amicus Curiae, supra note 50, p. 64. 27 Union of Concemed Scientists, The Climate Deception Dossiers (2018), supra note 219. 280 Ibid. 381 Id. pp. 64-65. 282 Joint Summary of the Amicus Curiae, supra note 50, p. 65.