1 2 and production, (2) refining and marketing, and (3) gas power and renewables. b. BP P.L.C. is the ultimate parent company for numerous subsidiaries that 3 find and produce oil and gas worldwide, that refine oil into fossil fuel products such as gasoline, 4 and that market and sell oil, refined petroleum products, and natural gas worldwide. BP P.L.C.’s 5 subsidiaries explore for oil and natural gas under a wide range of licensing, joint arrangement, and 6 other contractual agreements. 7 c. BP P.L.C. controls and has controlled companywide decisions about the 8 quantity and extent of fossil fuel production and sales, including those of its subsidiaries. BP P.L.C. 9 is the ultimate decisionmaker on fundamental decisions about the company’s core business, i.e., 10 the level of companywide fossil fuels to produce, including production among BP P.L.C.’s 11 subsidiaries. For instance, BP P.L.C. reported that in 2016–2017 it brought online thirteen major 12 exploration and production projects, which contributed to a 12% increase in the BP group’s overall 13 fossil fuel product production. These projects were carried out by BP P.L.C.’s subsidiaries. Based 14 on these projects, BP P.L.C. expects the company to deliver to customers 900,000 barrels of new 15 product per day by 2021. BP P.L.C. further reported that in 2017 it sanctioned three new 16 exploration projects in Trinidad, India, and the Gulf of Mexico and added 143% reserves 17 replacement for the group of entities over which it is the ultimate parent company. 18 d. BP P.L.C. makes fossil fuel production decisions for the entire BP group 19 based on a number of factors, including climate change. BP P.L.C.’s Board, an individual/subset 20 of the Board, or a committee appointed by the Board, is the highest level within the company with 21 direct responsibility for climate change policy. BP P.L.C.’s chief executive is responsible for 22 maintaining the BP group’s system of internal control that governs the BP group’s business 23 conduct. BP P.L.C. reviews climate change risks facing the BP group through two executive 24 committees chaired by the group chief executive and one working group chaired by the executive 25 vice president and group chief of staff, as part of BP group’s established management structure. 26 27 e. BP P.L.C. does substantial fossil-fuel related business in the United States, by marketing through licensure; franchising its petroleum products in the U.S. under the BP, 28 SHER EDLING LLP COMPLAINT 11