Bloom Environmental
Commitment Policy

This policy sets out Bloom's legally binding environmental commitments, the standards to which those commitments are held, and the frameworks under which they are made. It exists to be specific, verifiable, and honest - not to perform sustainability, but to practise it.

1. Governing frameworks

Bloom's environmental commitments are made in accordance with and informed by the following legal and voluntary frameworks:

• Kenya Environmental Management and Co-ordination Act (EMCA), Cap. 387 (1999, as amended 2015) - Kenya's primary environmental legislation, administered by the National Environment Management Authority (NEMA). Section 49 of the Act promotes tree planting and renewable energy use by organisations operating in Kenya.
• Kenya Climate Change Act, No. 11 of 2016 - establishes the regulatory framework for Kenya's response to climate change, including obligations on organisations to support low-carbon development.
• Paris Agreement (2015) - international treaty on climate change, to which Kenya is a signatory. Bloom's commitments align with Article 2 goals to limit global warming and support climate-resilient development.
• EU Green Claims Directive (Directive 2024/825 on Empowering Consumers for the Green Transition) - applicable to Bloom's communications with EU-based users. Bloom's environmental claims comply with the Directive's requirement that claims be specific, verifiable, backed by evidence, and not misleading. Enforcement begins 27 September 2026.
• FTC Green Guides (16 CFR Part 260) - applicable to Bloom's communications with US-based users. Bloom's claims avoid unqualified broad terms and are substantiated with specific evidence as required by the Guides.
• UK Competition and Markets Authority (CMA) Green Claims Code (2021) - applicable to UK-based users. Claims are truthful, clear, not omitting material information, and capable of being substantiated.
• UN Sustainable Development Goals - specifically SDG 13 (Climate Action) and SDG 15 (Life on Land). Bloom's reforestation programme directly supports the goals of protecting, restoring and promoting sustainable use of terrestrial ecosystems.

2. The 1% revenue pledge

Bloom commits to contributing a minimum of 1% of gross revenue in each financial year to verified reforestation and environmental restoration projects. This is a binding corporate commitment, not a discretionary charitable act.

How "gross revenue" is calculated

For the purposes of this pledge, gross revenue means all revenue received by Bloom from subscription plans, in-app purchases, and membership contributions, before deduction of any costs, taxes, or expenses. It does not include refunds already returned to users.

Payment timing

Contributions are calculated quarterly and disbursed within 30 days of the end of each quarter. Where revenue is pre-revenue (as during the current founding membership phase), Bloom's founder makes a personal contribution in lieu, which is recorded in the annual impact report.

Minimum floor

Regardless of revenue in any given year, Bloom commits to a minimum annual contribution of the equivalent of 100 verified trees to its reforestation partner(s), funded from operating budget where necessary.

3. Reforestation partner

Bloom's primary reforestation partner is Eden Reforestation Projects (legal entity: Eden Projects, Inc., a registered 501(c)(3) non-profit organisation). Eden has planted over 500 million trees across 10 countries including East Africa, and publishes independently verified project data.

Bloom may add or substitute partners where doing so increases the impact, transparency, or geographical relevance of contributions. Any change of partner will be disclosed in the annual impact report and updated in this policy. Users who have opted into the Grow Programme will be notified directly.

Verification

All tree planting is verified by Eden Reforestation Projects' own monitoring protocols, which include GPS-tagged planting records and satellite imagery review. Bloom does not make independent carbon credit claims against these trees.

4. The Grow Programme

The Grow Programme allows Bloom users to voluntarily contribute to reforestation above and beyond Bloom's 1% pledge. Participation is strictly opt-in and operates as follows:

• Free tier: All users benefit from Bloom's 1% pledge at no additional cost. No action is required.
• Monthly add-on (£0.50/month): Users who opt in to the Grow Programme add-on when paid plans launch will have £0.50 added to their monthly subscription. 100% of this amount is directed to Eden Reforestation Projects. Bloom does not retain a fee. One verified tree is planted per month per opted-in user. Proof of planting is accessible via the annual impact report.
• Direct contributions: Users may contribute directly to Eden Reforestation Projects at any time via the link provided on the Bloom website. Bloom matches direct contributions from its 1% pledge up to a total matching cap of £500 per quarter, disclosed in the annual impact report.

The Grow Programme is not a financial product, investment, or charitable collection by Bloom. Bloom acts as a payment facilitator directing 100% of opted-in contributions to a named third-party organisation. Users retain the right to cancel participation at any time.

5. Carbon neutrality claim

Bloom states that its digital operations are operationally carbon neutral by virtue of operating exclusively on Cloudflare's infrastructure, which is powered by 100% renewable energy. This claim is limited in scope to Bloom's direct operational carbon footprint (Scope 1 and 2 emissions). It does not extend to Scope 3 emissions (including user device usage, or supply chain emissions of third-party software).

In compliance with the EU Green Claims Directive, Bloom does not claim to be "carbon neutral" in an unqualified sense. The claim is qualified as operational and infrastructure-based, and rests on Cloudflare's published environmental commitments, which are independently auditable.

Bloom does not purchase carbon offsets to support this claim. The claim rests solely on the renewable energy source of the infrastructure used.

6. Anti-greenwashing compliance

Bloom is committed to making only accurate, specific, and substantiated environmental claims. In accordance with EU Directive 2024/825, the FTC Green Guides, and the CMA Green Claims Code, Bloom:

• Does not use the terms "eco-friendly", "green", "sustainable", or "net zero" without specific qualification and supporting evidence
• Does not claim to offset emissions through tree planting - trees are planted as a positive contribution to biodiversity and restoration, not as a carbon accounting mechanism
• Does not make forward-looking environmental claims without a public implementation plan (this policy constitutes that plan)
• Does not use self-certified sustainability labels - all verified tree planting is attributed to and verifiable through Eden Reforestation Projects
• Acknowledges that Bloom is a small, pre-revenue company and that the scale of its current environmental impact is proportionate to its size

7. Annual impact report

Bloom will publish an annual Environmental Impact Report no later than 31 March each year, covering the preceding financial year. The report will include:

• Total gross revenue and the 1% contribution amount
• Number of trees planted, verified by Eden Reforestation Projects
• Number of users enrolled in the Grow Programme and total contributions directed
• Any direct contribution matching executed
• Changes to partner organisations or this policy
• An honest assessment of what Bloom did not achieve and why

The first report will be published by 31 March 2027, covering the period from Bloom's first revenue to 31 December 2026. Reports will be publicly accessible at mybloomworld.org and archived permanently.

8. Limitation and modification

Bloom's environmental commitments are binding subject to the following conditions:

• The 1% pledge applies from the date Bloom receives its first subscription revenue
• In the event of insolvency, administration, or cessation of trading, environmental obligations will be settled as far as practicable from remaining assets
• Bloom may modify contribution partners, programme mechanics, or reporting formats, provided the underlying commitment (minimum 1% of gross revenue to verified reforestation) is maintained
• Material changes to this policy will be notified to Grow Programme participants at least 30 days in advance
• This policy does not create rights in favour of third parties except where expressly stated

Nothing in this policy limits or replaces Bloom's obligations under the Kenya EMCA, the Kenya Climate Change Act, or any other applicable environmental law.

9. Contact

Questions about this policy or Bloom's environmental commitments should be directed to:

Environmental Commitments
environment@mybloomworld.org
Response within 10 business days.