Memorandum for the Petitioners |130 8.170.In order to effectively comply with the UNGPs, the respondent Carbon Majors should prepare and publish detailed business plans describing how they will adjust their operations and activities so as to avoid infringing on human rights and remedy the human rights harms that have occurred.5° 8.171.To reiterate, based on petitioners’ expert submissions summarized in Annexes “D” and “E” and in Part V D.8 hereof, there is no evidence that respondent Carbon Majors have adequately and transparently taken the following actions to-date: a) Align their business models to a global average temperature level that avoids or minimizes dangerous anthropogenic interference with the climate system as evidenced by the best available science, and at the very minimum with the politically agreed 1.5°C temperature goal in the Paris Agreement and a carbon budget that provides the greatest possibility of keeping warming below 1.5°C; b) Take responsibility for the actual, real emissions from its products and operations, and not the company’s “net carbon footprint,” which is defined as the emissions per unit of energy the company sells;°!! c) Adequately acknowledge the impacts of climate change on the exercise of human rights since they first became aware of the potential climate risks and into the future;$! d) e) f) Renounce policy;*!? disinformation on climate science and Include climate change as a human rights matter in human rights due diligence;$! 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 in the Philippines;°'> and 610 Joint Summary of the Amicus Curiae, supra note 50, p. 65. 611 Muttitt, G. (20 May 2019), Shell’s Emissions Still Going Up Despite Accounting Device, available at http://priceofoil.org/2019/05/20/shell-emissions-still-going-up-despite-accounting-trick/ (last accessed on 06 September 2019). 612 Joint Summary of the Amicus Curiae, supra note 50, p. 64. 613 Union of Concerned Scientists, The Climate Deception Dossiers (2018), supra note 219. 814 bid. 615 Id. pp. 64-65.