Memorandum for the Petitioners |164 a balance of probabilities that the event has been caused by climate change”””); and f) H. Remedies (e.g. enforcement).”° damages, injunctive relief, and The Honorable Commission should recommend that the Philippine government develops a National Action Plan environment, on and climate based on the UNGPs’*! business, change, 9,28. To petitioners’ knowledge, the Philippine government has not embarked on the creation of a National Action Plan on business and human rights.”>? In light of the significant harms to human rights being suffered by the Filipino people as a result of climate change, a National Action Plan on business and human rights should cover environmental and climate change matters. 9.29. The Honorable Commission’s National Inquiry provides a baseline for such a plan. The process in developing the plan should be inclusive, ie. “go to villages, go to the barangays.””*? Among other things, the plan needs to ensure equity on climate action and support the development of “coherent state policy on corporate reporting on [financial and] non- financial matters.”7*4 I. The Honorable recommend Commission that should governments -- strengthen, or including the Philippines and other countries where the respondent Carbon Majors are domiciled and/or operate -- enhance, explore new ways to fulfill their international duty of cooperation, including but not limited to, further regulation of the Carbon Majors to fully address the human _ rights impacts of climate change 749 See Exhibit “WWWWWWWWW?" to “WWWWWWWWW-50,” supra note 744. 750 Wewerinke-Singh, M., supra note 742, p. 9. 71 Rosales, L., TSN dated 11-12 December 2018, pp. 89-90, supra note 667. 782 For more information, see National Action Plans on Business and Human Rights, available at https://globalnaps.org/country/philippines/ (last accessed on 12 September 2019). 753 Rosales, L., TSN dated 11-12 December 2018, p. 90, supra note 667. 754 Id, p.91.