King & Wood Mallesons
Regarding
Shandong Shengli Co., Ltd.
Issuance of Shares and Payment of Cash for Asset Acquisition and Raising of Supporting Funds and Related-Party Transactions
Supplementary Legal Opinion (I)
July 2026
To: Shandong Shengli Co., Ltd.
King & Wood Mallesons (the "Firm") was engaged by Shengli Co., Ltd. (the "Company") to serve as special legal counsel for the Company's current reorganization. In accordance with the Company Law, the Securities Law, the Administrative Measures for the Material Asset Reorganization of Listed Companies, the Administrative Measures for Securities Legal Business of Law Firms, and the Practice Rules for Securities Legal Business of Law Firms (Trial), as well as other applicable laws, administrative regulations, and China Securities Regulatory Commission (CSRC) requirements, the Firm issued the "King & Wood Mallesons Legal Opinion on Shandong Shengli Co., Ltd.'s Issuance of Shares and Payment of Cash for Asset Acquisition and Raising of Supporting Funds and Related-Party Transactions" (the "Legal Opinion") on May 25, 2026.
The Firm now issues this "King & Wood Mallesons Supplementary Legal Opinion (I) on Shandong Shengli Co., Ltd.'s Issuance of Shares and Payment of Cash for Asset Acquisition and Raising of Supporting Funds and Related-Party Transactions" (the "Supplementary Legal Opinion") in response to the Shenzhen Stock Exchange's "Inquiry Letter [2026] No. 130011" regarding the Company's application for the aforementioned transaction.
In accordance with the relevant laws and regulations, the Firm and its handling attorneys have strictly performed their statutory duties, adhered to the principles of diligence and good faith, and conducted sufficient verification of the matters related to this transaction. We guarantee that the facts identified in this Supplementary Legal Opinion are true, accurate, and complete, and that the conclusions reached are legal and accurate, with no false records, misleading statements, or material omissions.
This Supplementary Legal Opinion serves as a supplement to the previously issued Legal Opinion and constitutes an integral part thereof. The premises and assumptions stated in the Legal Opinion apply equally to this Supplementary Legal Opinion. Terms and abbreviations used herein have the same meanings as those in the Legal Opinion, unless otherwise specified.
This Supplementary Legal Opinion is intended solely for the Company's use in connection with this transaction and may not be used for any other purpose. The Firm consents to the inclusion of this Supplementary Legal Opinion as a required legal document for the transaction and assumes legal responsibility accordingly.
The Firm has verified the documents and facts provided by the relevant parties and hereby issues this Supplementary Legal Opinion as follows:
Table of Contents
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Question 1: Regarding Operating Conditions and Sustainability of Operations 4
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Question 3: Regarding Related-Party Transactions 49
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Question 5: Regarding Investee Companies 52
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Question 6: Regarding Asset Divestiture 55
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Question 7: Regarding Compliance 58
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Question 8: Regarding Transaction Arrangements 151
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Question 1: Regarding Operating Conditions and Sustainability of Operations