Memorandum for the Petitioners |125 8.153.Notably, under Section 2, Article IJ of the 1987 Philippine Constitution, the Philippines adopts the generally accepted principles of international law as part of the law of the land.*® Honorable Commission in its investigation. This should guide the 8.154.In any event, with due respect, petitioners submit that the Honorable Commission should take a purposive and holistic approach to applying human rights standards in its investigation. 86 ~To assess the respondent Carbon Majors’ responsibility, fundamental principles of legal and moral responsibility must both be considered. These include the respondents’ knowledge or notice of potential harms, whether the harms were reasonably foreseeable, the opportunity to avoid or reduce those harms, and whether the harms were caused by their actions— all clearly set out in Part V (D) hereof (Material Facts as Established by Evidence).°%” 8.155.Based on the pieces of evidence and analyses presented by the petitioners, the expert witnesses, and the amici, there is consensus that respondent Carbon Majors have substantial responsibilities to ensure their products and operations do not contribute to human rights impacts, impairments, infringements, abuses, and/or violations arising from climate change, as well as to provide remedy and redress where such violations occur. 8.156.Based on the information available to the petitioners, the respondents have failed to fulfill these duties. The respondent Carbon Majors’ past and current business models and activities contributed to climate-related human rights violations in the Philippines and beyond. The severity of these human rights impacts, impairments, infringements, abuses, and/or violations will continue to grow unless the respondents implement measures consistent with the UNGPs and other applicable norms.*** The respondent Carbon Majors’ responsibility should be assessed on a corporate group basis 8.157. The Interpretive Guide to the Guiding Principles (hereinafter, “Interpretive Guide”) confirms that an enterprise can contribute to an adverse cle-ii (last accessed on 12 al 987-constitution/#arti offici gov.ph/constitutions/1 /Avww. gazette. 585 See https: September 2019). 586 Id. p. 18. 587 Jq_, p. 60. This summary was compiled with inputs by the Center for International Environmental Law (CIEL), Asia Pacific Forum of National Human Rights Institutions & the Global Alliance of National Human Rights Institutions (APF & GANHRI), ClientEarth, and Plan B. This is based on their previously submitted amicus curiae briefs as well as relevant updates. 588 Ibid.