Legal Opinion on Changchun High-Tech Industries (Group) Inc. 2026 Restricted Stock Incentive Plan (Draft)

Legal Opinion on Changchun High-Tech Industries (Group) Inc. 2026 Restricted Stock Incentive Plan (Draft)

To: Changchun High-Tech Industries (Group) Inc.

Based on the "Lawyer Service Agreement" signed between our firm and Changchun High-Tech, our firm has been retained by Changchun High-Tech to serve as the dedicated legal advisor for this incentive plan. Our lawyers, in accordance with the Company Law, Securities Law, Management Measures, Listing Rules, and other relevant laws, administrative regulations, rules, and normative documents, as well as the relevant regulations of the China Securities Regulatory Commission (CSRC) and the Shenzhen Stock Exchange (SZSE), and adhering to the generally accepted business standards, ethical norms, and diligence principles of the legal profession, hereby issue this legal opinion on matters related to the incentive plan.

The issuance of this legal opinion is subject to the following statements by our lawyers:

1. Our lawyers express legal opinions solely based on facts that have occurred or existed prior to the issuance date of this legal opinion, and based on the currently effective laws, administrative regulations, rules, normative documents of China, and the relevant regulations of the CSRC and the SZSE. No legal opinions are expressed based on any laws outside of China.

2. In accordance with the Securities Law, the Measures for the Administration of Securities Law Business of Law Firms, and the Practice Rules for Securities Law Business of Law Firms (Trial), our lawyers have strictly performed their statutory duties, adhered to the principles of diligence and good faith, and conducted thorough investigations and verifications of facts that have occurred or existed prior to the issuance date of this legal opinion. We guarantee that the facts determined in this legal opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without any false statements, misleading representations, or material omissions, and we assume corresponding legal responsibilities.

3. Our lawyers only express opinions on legal issues related to this incentive plan and do not express opinions on the reasonableness of the stock value, performance standards, or other non-legal professional matters involved in this incentive plan. Any reference to financial data or conclusions in this legal opinion does not imply any express or implied guarantee of the truthfulness and accuracy of such data or conclusions.

4. This legal opinion is for the sole use of Changchun High-Tech for the purpose of implementing this incentive plan and shall not be used for any other purpose. Our lawyers agree that Changchun High-Tech may submit this legal opinion as a required legal document for this incentive plan along with other materials, and we shall bear responsibility for this legal opinion in accordance with the law.

5. For facts that are crucial to this legal opinion but cannot be independently verified, our lawyers will rely on certificates, testimony, or documents issued or provided by government departments, judicial organs, the company, or other relevant entities or individuals to issue this legal opinion.

6. The company has guaranteed that it has provided our lawyers with all necessary factual materials, approval documents, certificates, and other relevant documents for the issuance of this legal opinion, and confirms that all documents provided by the company are true, accurate, legal, effective, and complete, without any false statements, misleading representations, or material omissions, and that all signatures and seals on the documents are authentic, and all copies or duplicates are identical to the originals or the authentic versions.

To issue this legal opinion, our lawyers have reviewed the facts and legal documents related to the following aspects of this incentive plan:

1. Eligibility of the incentive plan;

2. Legality and compliance of the incentive plan's content;

3. Legal procedures involved in the incentive plan;

4. Incentive recipients of the incentive plan;

5. Information disclosure of the incentive plan;

6. The company does not provide financial assistance to incentive recipients;

7. Impact of the implementation of the incentive plan on the company and all shareholders;

8. Recusal of related directors in the voting for the incentive plan.