Kangda Law Firm
Beijing Kangda Law Firm
Supplementary Legal Opinion (I)
Regarding Xi'an International Medical Investment Co., Ltd.'s Private Placement of Shares
To: Xi'an International Medical Investment Co., Ltd.
Kangda Stock Issuance Letter (2026) No. 0030-1
Beijing Kangda Law Firm (hereinafter referred to as the "Firm") serves as the special legal advisor for Xi'an International Medical Investment Co., Ltd. (hereinafter referred to as the "Issuer" or the "Company") in its application for a private placement of shares (hereinafter referred to as the "Offering"). On April 2026, the Firm issued the "Lawyer's Work Report of Beijing Kangda Law Firm Regarding Xi'an International Medical Investment Co., Ltd.'s Private Placement of Shares" (hereinafter referred to as the "Work Report") and the "Legal Opinion of Beijing Kangda Law Firm Regarding Xi'an International Medical Investment Co., Ltd.'s Private Placement of Shares" (hereinafter referred to as the "Legal Opinion").
Given that the Shenzhen Stock Exchange issued the "Review Inquiry Letter [2026] No. 120028" regarding the application for a private placement of shares by Xi'an International Medical Investment Co., Ltd. on May 12, 2026, and the Issuer published its "2025 Annual Report" and "2026 First Quarterly Report" on April 24, 2026, in accordance with the requirements of the Shenzhen Stock Exchange and adhering to the universally recognized business standards, ethical norms, and diligence of the legal profession, the Firm's lawyers have conducted supplementary verification on the relevant legal issues involved in the "Review Inquiry Letter" and changes in the Issuer's situation from October 1, 2025, to March 31, 2026 (hereinafter referred to as the "Period") up to the date of issuance of this Supplementary Legal Opinion, and hereby issue this Supplementary Legal Opinion.
Given that the Issuer has announced its "2025 Annual Report" and "2026 First Quarterly Report," the reporting period for the Issuer has been changed to January 1, 2023, to March 31, 2026. Except for the aforementioned matters, the declarations and abbreviations used by the Firm's lawyers in the "Legal Opinion" remain applicable to this Supplementary Legal Opinion.
The Firm's lawyers agree that this Supplementary Legal Opinion shall be submitted together with other materials as a legal document required for the Issuer's application for this Offering, and the Firm shall be legally responsible for this Supplementary Legal Opinion. This Supplementary Legal Opinion is for the purpose of applying for this Offering only and shall not be used for any other purpose.
In accordance with the requirements of the "Company Law," "Securities Law," and other relevant laws, regulations, and normative documents, and in accordance with the business standards and ethical norms universally recognized by the legal profession, the Firm's lawyers hereby issue the supplementary legal opinion as follows:
Part One: Response to Review Inquiries
Inquiry One