Memorandum for the Petitioners | 71 have contributed to climate change, to impose on them specific and particular obligations in respect of the human rights impacts of climate change.”””* 6.13. References to the respondents in the Petition, Consolidated Reply, and this memorandum “should be taken as a reference to the parent entity or entities in whose name the accounts of the group are consolidated in accordance with the rules of the jurisdiction in which the parent is incorporated or listed for trading on a stock exchange. This is the intent of the petitioners’ pleadings, and as supported by the UNGPs, apply to “all business enterprises, both transnational and others, regardless of their size, sector, location, ownership and structure.”?”? 6.14. For purposes of issuing a final report and/or resolution concerning this National Inquiry, the Honorable Commission can “adopt an enterprise theory of corporate personhood[;] meaning[,] that the activities of the whole group of companies (and specifically the greenhouse gas emissions attributable to the group as a whole) should be aggregated and attributed to the parent entity.” E. Respondents’ moral and __ legal responsibility under general principles of tort and human rights law 6.15. Finally, under fundamental principles of responsibility that are common to judicial systems around the world, respondents can ultimately be held legally responsible for the harms being suffered by communities. The fossil fuel companies had early awareness, notice, and actual knowledge of the role of coal, oil, and gas products in causing climate change and the reasonably foreseeable human rights harms resulting from climate impacts. 6.16. Significantly, fossil fuel companies had the opportunity to avoid or reduce those harms. However, their past and current activities -- including the extraction, marketing, and sale of fossil fuels -- and past and current efforts to undermine climate science and solutions have contributed and continue to materially contribute to the climate damage resulting in human rights harms*°! to petitioners and Filipinos, in general. 298 Joint Summary of the Amicus Curiae, supra note 50, p. 62. 29 Ibid. 300 Ibid. 3°! bid.