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King & Wood Mallesons
Legal Opinion on the 2026 Annual Issuance of Shares to Specific Targets by Digital China Information Service Group Co., Ltd.
To: Digital China Information Service Group Co., Ltd.
King & Wood Mallesons (hereinafter referred to as "the Firm") has been engaged by Digital China Information Service Group Co., Ltd. (hereinafter referred to as "the Issuer") to act as special legal counsel for the Issuer's 2026 annual issuance of shares to specific targets (hereinafter referred to as "this Issuance").
The Firm has issued this legal opinion in accordance with the Securities Law of the People's Republic of China, the Company Law of the People's Republic of China, the Administrative Measures for the Registration of Securities Issuance by Listed Companies, the Administrative Measures for Securities Legal Business of Law Firms, the Practice Rules for Securities Legal Business of Law Firms (Trial), the Stock Listing Rules of the Shenzhen Stock Exchange, and other applicable laws, administrative regulations, rules, and normative documents of the People's Republic of China, as well as relevant regulations of the China Securities Regulatory Commission (hereinafter referred to as "CSRC"), following recognized professional standards, ethical norms, and the spirit of diligence and responsibility.
The Firm and its handling lawyers have strictly performed their statutory duties, adhered to the principles of diligence, responsibility, and good faith, and conducted sufficient verification of matters related to this Issuance based on the aforementioned regulations and facts existing prior to the date of this legal opinion. We guarantee that the facts identified in this legal opinion are true, accurate, and complete, and that the conclusions expressed regarding this Issuance are legal and accurate, free from false records, misleading statements, or major omissions, and we assume corresponding legal liabilities.
Introduction
To issue this legal opinion, the Firm has prepared and implemented a verification plan in accordance with the Administrative Measures for Securities Legal Business of Law Firms and the Practice Rules for Securities Legal Business of Law Firms, personally collected evidence, and reviewed documents required by regulations and other documents deemed necessary by the Firm. Based on the Issuer's guarantee that all materials provided are true, accurate, complete, and effective, and that there are no concealed records, false statements, or major omissions, the Firm has independently, objectively, and impartially applied methods such as interviews, written reviews, on-site investigations, inquiries, letters of confirmation, calculations, and re-checks to verify and confirm relevant facts.
In this legal opinion and the "Lawyer's Work Report of King & Wood Mallesons on the 2026 Annual Issuance of Shares to Specific Targets by Digital China Information Service Group Co., Ltd." (hereinafter referred to as the "Lawyer's Work Report"), the Firm expresses opinions only on legal issues related to this Issuance and does not express opinions on non-legal matters such as accounting, auditing, and asset appraisal. The Firm expresses opinions only based on current effective laws and regulations within the People's Republic of China.
This legal opinion and the Lawyer's Work Report are for the use of the Issuer for the purpose of this Issuance only and shall not be used for any other purpose. The Firm agrees that the Issuer may cite relevant content from this legal opinion or the Lawyer's Work Report in the "Prospectus" prepared for this Issuance or as required by the CSRC, provided that such citation does not lead to legal ambiguity or distortion.
Unless otherwise specified by the context, the following terms or abbreviations in the left column correspond to the meanings or full names in the right column: