Legal Opinion from Allbright Law Offices
Address:
501 Yincheng Middle Road, Shanghai Tower, 11/12 Floor, Pudong New District, Shanghai
Phone: 021-20511000; Fax: 021-20511999
Postal Code: 200120
To: Zhongjin Mining Co., Ltd.
Allbright Law Offices (hereinafter referred to as "this firm") has been entrusted by Zhongjin Mining Co., Ltd. (hereinafter referred to as "the Company") to provide legal opinions regarding the convening of the first bondholders meeting for the "Zhongjin Convertible Bonds" 2026 (hereinafter referred to as "this bondholders meeting" or "this meeting"). This opinion is issued in accordance with 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 Administrative Measures for Convertible Corporate Bonds, and other relevant laws, regulations, and normative documents, as well as the Rules for the Bondholders Meeting of Zhongjin Mining Co., Ltd. (hereinafter referred to as "the Rules").
This legal opinion only addresses the qualifications of the convener of this bondholders meeting, the convening and holding procedures, the attendees of the meeting, and the voting procedures and results, confirming whether they comply with the provisions of the Company Law, Securities Law, and other relevant laws, regulations, normative documents, and the Rules. This opinion does not comment on the content of the proposals reviewed at the meeting or the truthfulness, accuracy, and completeness of the facts or data expressed in such proposals. This legal opinion is solely for the purpose of witnessing the Company's meeting and shall not be used for any other purposes.