Legal Opinion Letter
To: Gansu Engineering Consulting Group Co., Ltd.
According to the entrustment of Gansu Engineering Consulting Group Co., Ltd. (hereinafter referred to as "the Company") and based on the provisions of the Company Law of the People's Republic of China (hereinafter referred to as "the Company Law"), the Securities Law of the People's Republic of China (hereinafter referred to as "the Securities Law"), the Rules for Shareholders' Meetings of Listed Companies (CSRC Announcement [2025] No. 7) (hereinafter referred to as "the Shareholders' Meeting Rules"), the Corporate Governance Guidelines (revised in October 2025) (hereinafter referred to as "the Governance Guidelines"), and the Self-Regulatory Guidelines for Listed Companies on the Shenzhen Stock Exchange No. 1 - Standardized Operations for Main Board Listed Companies (revised in April 2026) (Shenzhen Stock Exchange [2026] No. 547) (hereinafter referred to as "the Standardized Operations Guidelines"), as well as the Articles of Association of Gansu Engineering Consulting Group Co., Ltd. (hereinafter referred to as "the Articles of Association") and the Rules of Procedure for Shareholders' Meetings of Gansu Engineering Consulting Group Co., Ltd. (hereinafter referred to as "the Rules of Procedure"), Shanghai Zhonglian (Lanzhou) Law Firm (hereinafter referred to as "this Firm") appointed lawyers Huo Jidong and Zhang Ruibo to attend the Company's 2025 Annual Shareholders' Meeting (hereinafter referred to as "this Meeting"). This legal opinion letter is issued regarding the matters related to the convening of this Meeting. This Firm agrees to announce this legal opinion letter together with the resolutions of this Meeting and shall bear corresponding responsibilities for the legal opinions issued by this Firm. The lawyers of this Firm express opinions only on the convening and holding procedures of this Meeting, the qualifications of the convener and attendees, the proposals reviewed at this Meeting, the voting procedures, and the voting results. This legal opinion letter is for the purpose of this Meeting only.
According to the requirements of relevant laws and regulations, and in accordance with the recognized business standards, ethical norms, and the spirit of diligence and responsibility in the legal profession, the lawyers of this Firm attended this Meeting and verified the relevant materials and facts. Based on the understanding of the facts and the interpretation of the law, the legal opinions are as follows:
I. Convening of this Meeting
(1) Convener of this Meeting
According to the Meeting Notice for this Meeting, this Meeting is convened by the Company's eighth Board of Directors.
(2) Convening Procedures of this Meeting
According to the resolution of the 24th meeting of the eighth Board of Directors, this Meeting is scheduled to be held on May 28, 2026. The eighth Board of Directors published the "Notice of the 2025 Annual Shareholders' Meeting of Gansu Engineering Consulting Group Co., Ltd." (hereinafter referred to as "the Meeting Notice") on April 24, 2026, on the Giant Tide Information Network (www.cninfo.com.cn), which specifies the convener, date and time of the meeting, method of holding the meeting, attendees, meeting location, equity registration date, matters for deliberation, and registration methods for the meeting. Since this Meeting adopts a combination of on-site voting and online voting, the Company has also clearly stated the voting time and procedures for online voting in the announcement. After verification and review by the lawyers of this Firm, the qualifications of the convener of this Meeting and the time, method, and content of the Meeting Notice comply with the provisions of the Company Law, the Shareholders' Meeting Rules, the Governance Guidelines, the Standardized Operations Guidelines, and other laws, administrative regulations, normative documents, as well as the Articles of Association and the Rules of Procedure.