Pulmonx Corporation California Compliance Disclosure

September 9, 2025

Pulmonx Corporation (“Pulmonx”) is committed to establishing and maintaining a “Comprehensive Compliance Program” (“Compliance Program”) that is in accordance with the “Compliance Program Guidance for Pharmaceutical Manufacturers,” developed by the United States Department of Health and Human Services Office of Inspector General (OIG).

Pulmonx’s Compliance Program includes policies and procedures which are designed to be in compliance with the AdvaMed Code of Ethics on Interactions with Healthcare Professionals, the Anti-Kickback Statute, the Physician Payments Sunshine Act, the U.S. Foreign Corrupt Practices Act of 1977, as amended, and other laws applicable to Pulmonx where it conducts its business globally.

The Pulmonx Compliance Program contains the OIG’s elements of an effective compliance program, including: (i) written policies and procedures; (ii) oversight by senior leadership, including a Compliance Officer; (iii) regular compliance training and education; (iv) open lines of communication; (v) risk assessment, auditing and monitoring; and (vi) procedures for responding to instances of noncompliance.

This California Compliance Disclosure (“Compliance Disclosure”) is provided pursuant to the requirements of CAL. HEALTH & SAFETY CODE §§ 119400 – 119402 (the “California Code”). Pulmonx believes that it is in compliance with its Compliance Program and the provisions of the California Code as of the date of this Compliance Disclosure. This Compliance Disclosure is made solely for the purpose of complying with the California Code. To obtain a copy of our Compliance Program documents, please contact the Pulmonx Compliance Officer at 833-976-2024.