14 2.19. While the Petition and the Honorable Commission’s Order are directed at Carbon Major’s parent entities, the subsidiaries are also implicated. The headquarters and principal office addresses were provided in Annex “C” of the Petition. Additionally, the petitioners provided in the same annex the addresses of related entities appearing to exist in the Philippines.34 It should be abundantly clear to the companies listed in the Petition and Annex “C” thereof, including parent entities and subsidiaries, that they are the intended recipients of the Petition and must engage in a coordinated manner as corporate groups in the investigation. 2.20. Nevertheless, the Omnibus Rules of the Commission allows the naming or identifying of the respondents even in the course of investigation.35 The petitioners, therefore, encourage respondents Chevron, i.e. Chevron Corporation, and UK Coal, i.e. UK Coal Production Limited, through the PwC, to volunteer their companies’ names, as registered or preferred, and other information, and cooperate with the Honorable Commission in this national public inquiry. 2.21. Otherwise, respondents can expect that the petitioners will not stop and will seek for the truth through means allowed under the Omnibus Rules of the Commission and special rules of national public inquiry, or based on the wise discretion of the Honorable Commission. It is unacceptable that respondents excuse themselves from an important investigation into their human rights responsibility arising from climate change, based on technicalities. B.3. The Honorable Commission’s broad investigative mandate encompasses the Carbon Majors’ corporate groups, regardless if there are entities registered or domiciled or transacting or doing business in the Philippines. 2.22. Respondents Apache,36 CEMEX S.A.B. de C.V. (hereinafter, “Cemex”),37 ConocoPhillips,38 Marathon Oil,39 Peabody Energy Corporation (hereinafter, “Peabody”),40 Repsol, S.A. and Repsol Oil & Gas Canada Inc. (hereinafter, “Repsol”),41 Shell,42 Taiheiyo,43 on their part, raise the 34 See Annex “C” to the Petition. “The party shall be identified as a respondent when the person is named/identified as such in the complaint or in the course of investigation. . . .” (Section 12, Rule 4 of the Omnibus Rules of the Commission) 36 Letter dated 12 September 2016 (Ad Cautelam Comment on Petition), No. II, pp. 2-3 thereof. 37 Entry of Special Appearance with Motion to Dismiss dated 14 September 2016, No. 19, p. 16, thereof. 38 Letter dated 12 September 2016 (Ad Cautelam Comment on Petition), No. II, pp. 2-3 thereof. 39 Marathon’s Ad Cautelam Comment on Petition. 40 Special Appearance and Motion to Dismiss dated 15 September 2016, No. 4, p. 2 and No. 5, p. 3 thereof. 41 Special Appearance and Motion to Dismiss dated 22 September 2016, pp. 3-7 thereof. 42 Motion to Dismiss Ex Abundanti Ad Cautelam dated 09 September 2016, No. II (B), pp. 61-65 thereof. 43 Taiheiyo’s Motion to Dismiss. 35

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