Memorandum for the Petitioners |126 human rights impacts through the legal sale of its products.*’ Each business is expected to carry out its human rights responsibilities autonomously even if the individual roles and contributions to climate change differ, as every business, regardless of size or sector, is expected to respect human rights under Principle 14 of UNGPs.*°° An enterprise theory of corporate personhood entails that the activities of the whole group of companies -- and specifically the GHG emissions attributable to the group as a whole -- should be aggregated and attributed to the parent entity. The UN Guiding Principles on Business and Human Rights: Implementing the UN “protect, respect, and remedy” framework 8.158. Businesses have significant responsibilities to respect human rights, and States must ensure corporate compliance with these responsibilities and provide for corporate accountability and access to justice when standards are not met.*®! States also have direct obligations, known as duties, because of the undertakings that they have willingly made through treaties or other sources of law. 8.159.Business enterprises, on the other hand, have significant responsibilities, as opposed to direct obligations, under international law. This does not diminish the significance of corporate responsibilities, as they can also be drawn from national legislation or guidelines following States’ implementation of their international obligations.°” 8.160.As mentioned, the responsibility to respect human rights arises from a global standard of expected conduct for all business enterprises wherever they operate. This exists over and above compliance with national laws and regulations protecting human rights and independently of States’ abilities or willingness to fulfill their own human rights obligations. This responsibility also exists independently of an enterprise’s own commitment to human rights.°” 589 United Nations Office of the High Commissioner of Human Rights (2012), The Corporate Responsibility to Respect Human Rights: An Interpretive Guide, pp. 46-49 (hereinafter, “Interpretive Guide”), available at https://www.ohchr.org/Documents/Publications/HR.PUB.12.2_En.pdf (last accessed 06 September 2019) 59 See Exhibit “QQQ” to “QQQ-8,” Profile and Statement of Michael K. Addo, dated 20 May 2018, p. 8. 591 De Schutter, O., et al., (2012), Commentary to the Maastricht principles on extraterritorial obligations of states in the area of economic, social and cultural rights. Human Rights Quarterly, 34 (4), pp. 1084- 1169. ISSN 0275-0392, available at http://eprints.Ise.ac.uk/47404/1/__Ise.ac.uk_storage_LIBRARY_Secondary_libfile_shared_repository_Cont ent_Salomon,%20M_Commentary%20to%20Maastricht%20principles_Salomon_Commentary%20Maastri cht%20principles_2015.pdf (last accessed on 12 September 2019). 592 Addo. M., supra note 590, p. 8. 53 Interpretative Guide, supra note 589, pp. 13-14.