change, and accountability has become more robust. For example, the Office of the United Nations High Commissioner for Human Rights (OHCHR) affirmed that businesses, as human rights duty bearers, “must be accountable for their climate impacts and participate in climate change mitigation and adaptation efforts with full respect for human rights.”29 Furthermore, the recommendations that this Commission should make will direct the appropriate State Actor to fulfill its obligation to ensure that private actors do not violate the human rights of the Filipino people. International Laws, Norms, and Standards Support an Investigation Process by the Commission that Produces Recommendations to Prevent Future Human Rights Violations CIEL supports the Petitioners’ arguments that it is appropriate and within the Commission’s constitutional and procedural powers to apply the Guiding Principles to assess whether the conduct by the Carbon Majors satisfies a test of contributory causation to the human rights violations at issue. Here again, the Guiding Principles provide a standard. We agree with Amici Curiae’ Client Earth’s analysis that applying a test of contributory causation balanced by a standard of reasonableness is supported by the Interpretive Guide to the Guiding Principles. 30 Decades of research illustrates that the Carbon Majors’ contributions to increasing concentrations of greenhouse gas emissions in the atmosphere has been so substantial as to alter the condition of the global atmosphere, and, under the Guiding Principles, that would likely impose an obligation. Further, we support the Petitioners’ assertion that the Carbon Majors have failed to respect human rights where their contributions to climate change have infringed and are infringing on the human rights of others with continued and accelerated greenhouse gas emissions.31 By Failing to Disclose the Business Activities that Violate Human Rights, the Evidence Suggests that the Carbon Majors Have Acted and Continue to Act in a Manner Contrary to Due Diligence Obligations Further, CIEL supports the Petitioners’ and the Amici Curiae’s assertion that the Guiding Principles offer an appropriate standard to balance and assess the business enterprises of the Carbon Majors. Specifically, the Guiding Principles state that in order for business enterprises to meet its responsibility to respect human rights, a business should engage in a process or due diligence, to ensure that it does not infringe upon the rights of others.32 The due diligence process fuses two conceptually distinct processes, one is an investigation of facts, and the other is an 29 See Office of the High Commission for Human Rights (OHCHR), Discussion Paper: Understanding Human Rights and Climate Change, Submission of the OHCHR to the 21st Conference of the Parties to the United Nations Framework Convention on Climate Change (2015); see also Amicus Curiae Brief of Sabin Center for Climate Change Law, Columbia Law School (citing OHCHR, Discussion Paper: The Rights of Those Disproportionately Impacted by Climate Change (2016)). 30 See Amicus Curiae Brief, Client Earth at 60; (discussing the Interpretive Guide to the Guiding Principles included as Annex D). 31 Guiding Principles, supra note 27, at Part II: The Corporate Responsibility to Respect Human Rights. 32 See infra note 33 (interpreting the Protect, Resspect and Remedy: A Framework for Business and Human Rigghtss,” UN Doc A/HRC/8/5, para 24 and para. 56. 9