Memorandum for the Petitioners | 133 reflective of or contrary to some of their purported climate and human rights commitments, that include efforts to undermine climate science and action and continued investments in extraction of fossil fuels despite clear scientific requirements for a phase-out in order to protect people and ecosystems. B. Due diligence for Carbon Majors the respondent 8.181.The UNGPs are intended “to prevent business enterprises from escaping responsibility through the outsourcing of potentially harmful activities to others through their business relationships.”®’ This includes being held legally responsible for climate impacts. 8.182. As repeatedly asserted, business enterprises -- regardless of their level of contribution to GHGs, which caused and are causing climate change -- must conduct human rights due diligence. An effective human rights due diligence process in the context of climate change should ensure that the company has a strong governance framework by which corporate management acknowledges and describes how they assess and manage the impact of their operations’ contribution to climate change on human rights. To meet this obligation, respondent Carbon Majors should: 1. Implement processes to assess climate change-related human rights impacts of their products and activities; 2. Implement measures to rapidly reduce GHG emissions, including overseas production and activities, major subsidiaries and their entire supply chain; and 3. Make the relevant information and mitigation efforts public.°* 8.183. The application of the UNGPs, diligence, allows for a focused scrutiny on have taken and should be taking to fulfill respect human rights.° Some questions include: about their emissions especially the requirement of due the steps that respondents should their corporate responsibilities to that are relevant in this regard 27 ClientEarth, CIEL, APF-GANHRI, Plan B, Joint Summary of the Amicus Curiae, supra note 50, p. 65, citing Mark B. Taylor (CAR), Human Rights Due Diligence: The Role of the States (2013 Update), p. 13, available at 20 (last accessed on 12 September | 3-update-final.pdf www. bhrinlaw.org/icar-human-rights-due-diligence- 2019). 628 See Exhibit “DDDDDDDDD” to “DDDDDDDDD-3, Statement of Resource Person Kumi Naidoo, dated 06 December 2018, p. 9. 829 See Exhibit “CCCC” to “CCCC-6,” Statement of Statement of Dr. Marcos Orellana, p. 2, supra note 406.