Allbright Law Offices
Legal Opinion
To: Shenyang Chemical Co., Ltd.
Allbright Law Offices (hereinafter referred to as "the Firm") has been entrusted by Shenyang Chemical Co., Ltd. (hereinafter referred to as "the Company") to issue this Legal Opinion regarding the relevant matters concerning the Company's 2026 Second Extraordinary General Meeting (hereinafter referred to as "the EGM"). In accordance with the "Company Law of the People's Republic of China" (hereinafter referred to as "the Company Law"), the "Rules for Shareholders' Meetings of Listed Companies," and other relevant laws, regulations, and normative documents, as well as the "Articles of Association of Shenyang Chemical Co., Ltd." (hereinafter referred to as "the Articles of Association"), this Legal Opinion is hereby issued.
In order to issue this Legal Opinion, the Firm and its lawyers have strictly performed their statutory duties in accordance with the "Administrative Measures for Law Firms Engaging in Securities Legal Business" and the "Practice Rules for Securities Legal Business of Law Firms (Trial)," adhering to the principles of diligence and good faith. Necessary checks and verifications have been conducted on the matters related to the EGM, and relevant documents and materials deemed necessary by the Firm for issuing this Legal Opinion have been reviewed. The Firm participated in the entire process of the Company's EGM. The Firm guarantees 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 records, misleading statements, or material omissions, and the Firm is willing to bear corresponding legal responsibilities.
Accordingly, based on the requirements of the aforementioned laws, regulations, rules, and normative documents, and in accordance with the business standards, ethical norms, and spirit of diligence recognized by the legal profession, the Firm's lawyers hereby issue the following legal opinion:
I. Qualifications of the Convener and Procedures for Convening and Holding the EGM
(I) Convening of the EGM
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On July 24, 2026, the Company convened the fifteenth meeting of the tenth Board of Directors, which resolved to hold the 2026 Second Extraordinary General Meeting on August 10, 2026, at 14:30, through a combination of on-site and online voting.
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On July 25, 2026, the Company published an announcement on the website of the Shenzhen Stock Exchange and designated information disclosure media of the China Securities Regulatory Commission regarding the convening of the 2026 Second Extraordinary General Meeting of Shenyang Chemical Co., Ltd. The announcement specified the time, place, matters to be deliberated, attendees, registration methods, and registration and contact addresses for the EGM. The Company's Board of Directors fully disclosed the content of all proposals in accordance with the relevant provisions of the "Rules for Shareholders' Meetings of Listed Companies." The date of the announcement publication was more than 15 days prior to the EGM date.
(II) Holding of the EGM
- Method of Meeting
The EGM was held using a combination of on-site and online voting.
- On-site Meeting
The on-site meeting of the EGM was held as scheduled on August 10, 2026 (Monday) at 14:30 in the conference room of the Company's office building at No. 55, Shenxi East Road, Shenxi Area, Shenyang Economic and Technological Development Zone, presided over by Mr. Zhu Bin, Chairman of the Company.
- Online Voting
The Company provided an online voting platform for all shareholders through the Shenzhen Stock Exchange trading system and the internet voting system.
Online voting time: August 10, 2026, specifically:
① The online voting time through the Shenzhen Stock Exchange trading system was from 9:15-9:25 and 9:30-11:30, and 13:00-15:00 on August 10, 2026.
② The voting time through the Shenzhen Stock Exchange internet system was any time between 9:15 and 15:00 on August 10, 2026.