Amicus Curiae Brief presented by ClientEarth 21 November 2016 112. Principles 16 to 22 elaborate on the operationalization of each of these three requirements. In applying these principles to the human rights implications of climate change, the Commission could find that the Carbon Majors should: a. acknowledge, in their statement of policy created under Principle 16, the effect of climate change on the exercise of human rights now and into the future; b. include climate change as a human rights issue in human rights due diligence undertaken in accordance with Principle 17; c. identify and assess the specific human rights impacts of climate change arising from their operations and products, drawing on human rights expertise, and involving meaningful consultation with potentially affected groups and other relevant stakeholders (Principle 18); d. take appropriate action to mitigate the greenhouse gas emissions from their operations and products, which may (or may not) constitute a crucial relationship as defined in Principle 19, for some of the Carbon Majors; and e. track the effectiveness of their response by fully and adequately reporting on their total greenhouse gas emissions (including across the full life-cycle of their products), as well as proposed actions to mitigate their emissions into the future including appropriate emissions reduction targets, and diversification of energy sources. This should be transparently produced and documented, in order to fully comply with Principles 21 and 20. 54

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