Memorandum for the Petitioners |152 preventing persons within their jurisdiction against human rights abuses as a result of the conduct of corporate actors headquartered outside of their territory, such as by providing access to an effective remedy;” and f) As part of its “sovereign public trust obligations” and obligations to respect, protect, and fulfill human rights, the Philippine government should seek natural resource damages from the Carbon Majors for the harm done to the atmosphere and the climatic system.’!° The natural resource damage should be used to transparently fund a just transition for workers in the fossil fuel industry in the Philippines; climate research as independently identified by the country’s leading government and academic institutions, and adaptation, resiliency and emergency preparedness efforts; and mitigation measures, including renewable energy and natural climate solutions, to support the country’s ability to meet its international climate commitments under the UNFCCC and Paris Agreement. A.6. a) Findings concerning responsibility under the UNGPs and international jurisprudence | The Honorable Commission should take a purposive and holistic approach to applying human rights standards to the respondent Carbon Majors;”"! b) Businesses have the responsibility to respect and protect human rights, as described in the UNGPs and international jursiprudence;7!? c) The UNGPs require enterprises to assess, address, and take responsibility for the climate-related human rights impacts of their products and operations;’"? d) Given the significant human rights impacts change, the UNGPs apply to companies’ of climate direct and 709 Ibid., pp. 47-50. 110 Ibid. p. 54. 71 Id. p. 10. 712 Jd. p. 61, citing Kalifia and Lokono Peoples v. Suriname, inter-Am. Ct. H. R., Judgment (Merits, Reparations, and Costs), par. 224 (25 November 2015), available at http://www.corteidh.or.cr/docs/casos/articulos/seriec_309_ing.pdf (last accessed on 12 September 2019); Urbaser S.A. & Consorcio de Aguas Bilbao Bizkaia, Bilbao Biskaia Ur Partzuergoa v. The Argentine Republic, \CSID Case No. ARB/07/26, Award, par. 1999 (08 December 2016); Case against New TV S.A.L. and Karma Mohamed Tahsin al Khayat, STL-14-05/PT/AP/ARI26.1, Decision on Interlocutory Appeal Concerning Personal Jurisdiction in Contempt Proceedings, Special Tribunal for Lebanon, par. 46 (02 October 2014). 713 ClientEarth, Joint Summary of the Amicus Curiae, supra note 50, p. 76.