54 declined to respond, and thirty-three (33) companies did not acknowledge the BHRRC’s invitation. The written responses sent to BHRRC are publicly available on its website.217 3.2. Four (4) of the companies that responded to the BHRRC -ConocoPhillips, Peabody Energy, Repsol, and Rio Tinto -- also submitted responses to the Honorable Commission. The other seven (7) companies did not cooperate with the Honorable Commission’s request.218 However, the petitioners request the Commission to take cognizance of positions communicated to the BHHRC, as well as the non-response. Please see Annex “A” for a list of respondents that responded to BHRRC. 3.3. The responses received by BHRRC raise four (4) primary issues, whether: (a) the Honorable Commission has jurisdiction over the companies; (b) the confidentiality rules apply to the national public inquiry procedure; (c) the companies’ positions on climate change are adequate in light of the serious human rights risks posed to the petitioners; and (d) the companies’ internal policies and procedures on human rights require their active participation in the national public inquiry. These four issues are discussed below. B. The respondents’ vague challenges to the Honorable Commission’s jurisdiction are without merit. 3.4. Respondents ConocoPhillips and Rio Tinto London Ltd challenge the Honorable Commission’s personal jurisdiction over the companies due to the lack of operations,219 employees, projects, or operations in the Philippines.220 These issues have been addressed in the preceding section, and the arguments therein are repleaded in this section. 3.5. Respondent BHP Billiton contends that “certain of the prayers for relief in the Petition ask the Commission to adjudicate the petitioners’ claims against the respondents, including BHP Billiton, which would appear 217 Business & Human Rights Resource Centre, Fossil fuel firms respond to petition before Philippines Human Rights Commission on human rights & climate impacts, available at https://business-humanrights.org/en/fossil-fuel-cos-respond-to-petition-with-philippines-human-rightscommission-on-human-rights-climate-change-impacts, last accessed on 08 February 2017. 218 The seven companies that responded to BHRRC but not to the Commission are: Anglo American plc, BHP Billiton; BP plc, Eni S.p.A., Freeport-McMoRan Inc, Glencore plc, and PJSC LUKOIL. 219 ConocoPhillips, Letter to Business & Human Rights Resource Centre dated 19 October 2016, available at https://business-humanrights.org/en/fossil-fuel-cos-respond-to-petition-with-philippines-human-rightscommission-on-human-rights-climate-change-impacts, last accessed on 06 February 2017. 220 Rio Tinto London Ltd, Letter Ad Cautelam and without Submission to Jurisdiction to Commission Cadiz dated 10 October 2016, Business & Human Rights Resource Centre, 19 October 2016, available at https://business-humanrights.org/en/fossil-fuel-cos-respond-to-petition-with-philippines-human-rightscommission-on-human-rights-climate-change-impacts, last accessed on 06 February 2017.