comply with legal and regulatory mandates.50 Due diligence processes are commonly used to assess businesses’ compliance and practices related to labor, consumer protection, environmental, and securities laws, among other national legal regimes. In the United States, businesses must comply with disclosure requirements under securities laws as enforced by the Securities and Exchange Commission on the federal level and enforced by the State’s Attorneys General at the state level. ExxonMobil, one of the largest companies among the Carbon Majors, is currently being investigated by attorneys general from the Commonwealth of Massachusetts and the State of New York for concerns arising about what Exxon Mobil knew about climate change and when that information was disclosed to investors and consumers.51 These allegations are supported by documents collected by CIEL and others. Conclusion This Opinion and the Synthesis Report summarize an extensive collection of correspondences, scientific research, and other documents that describe the development of climate change knowledge and expertise since the early1900s. The documents provide evidence that demonstrates that the oil industry had knowledge of the harms caused by climate. These documents also demonstrate that the oil industry experts acted in ways contrary to principles of due diligence under international law and guidance. First, the oil industry continued to invest in technologies that would both expand fossil fuel exploration with full knowledge that accelerating the rate at which carbon dioxide concentrations would accumulate in the atmosphere would also accelerate the frequency and intensity of harms to the environment, human health, and ultimately human rights.52 Secondly, rather than taking action to mitigate the harms caused by industry operations, the oil industry engaged in a well-funded campaign of deception to avoid accountability and to avoid regulations that would have restricted profitable exploration and drilling operations. For these reasons, and the reasons provided in supplemental and amici briefs, we urge the Commission to conduct an investigation of the Carbon Majors as to their infringement of the human rights of the citizens of the Philippines. CIEL respectfully requests that the Commission accept this Opinion to assist in its National inquiry into the responsibility of the Carbon Majors for their contributions to climate change and human rights violations. 50 Id. On April 19, 2016, Attorney General Healey opened an investigation by issuing a civil investigative demand to ExxonMobil Corporation concerning violations of the Massachusetts consumer protection statute, M.G.L. c. 93A, Section 2 and its implementing regulations arising from Exxon’s (1) marketing and/or sale of energy and other fossil fuel derived products to consumers in the Commonwealth of Massachusetts, and (2) the marketing and or sale of securities as defined in M.G.L. c. 110A, Section 401(k), to investors in the Commonwealth. Specifically, the investigation seeks information regarding whether Exxon may have misled consumers and/or investors with respect to the impact of fossil fuels on climate change, and climate change-driven risks to Exxon business. Relevant filings are available at http://www.mass.gov/ago/bureaus/eeb/the-environmental-protection-division/exxoninvestigation.html; see also Jackie Wattles, SEC is latest regulator to investigate Exxon Mobil’s Accounting Practices, CNN Money, Sept. 20, 2016, available at http://money.cnn.com/2016/09/20/news/companies/exxonmobil-sec-investigation/(reporting that the U.S. Securities and Exchange Commission has asked for documents from Exxon and PricewaterhouseCoopers which audits the company’s financial documents). 52 See Synthesis Report, supra note 4. 51 12