Supplementary Legal Opinion of Beijing Zhonglun Law Firm on Runbei Aviation Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Objects (I)
Legal Opinion
According to the agreement in the Special Legal Service Contract signed between Runbei Aviation Technology Co., Ltd. (hereinafter referred to as "the Issuer" or "the Company") and Beijing Zhonglun Law Firm (hereinafter referred to as "this Firm"), this Firm has been entrusted by the Company to act as the special legal advisor for the Company's issuance of convertible bonds to unspecified objects (hereinafter referred to as "this Issuance").
In accordance with the Company Law, Securities Law, Regulations on the Administration of Securities Legal Services, Securities Legal Practice Rules, Registration Management Measures, and Reporting Rules No. 12, as well as relevant provisions from the China Securities Regulatory Commission and the stock exchange, this Firm has issued the "Legal Opinion on Runbei Aviation Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Objects" (hereinafter referred to as "the Original Legal Opinion") and the "Lawyer's Work Report on Runbei Aviation Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Objects" (hereinafter referred to as "the Lawyer's Work Report").
In response to the inquiry letter issued by the Shenzhen Stock Exchange Listing Review Center on May 14, 2026, regarding the review of Runbei Aviation Technology Co., Ltd.'s application for the issuance of convertible bonds to unspecified objects (hereinafter referred to as "the Inquiry Letter"), this Firm has conducted supplementary verification of the relevant matters concerning this Issuance and hereby issues this legal opinion. This legal opinion serves as a supplement to the Original Legal Opinion and the Lawyer's Work Report. The terms, names, abbreviations, and acronyms used in this legal opinion, unless otherwise specified, have the same meanings as in the Original Legal Opinion and the Lawyer's Work Report. All statements made in the Original Legal Opinion and the Lawyer's Work Report apply to this legal opinion.
This Firm has conducted verification and validation of the documents and relevant facts provided by the Issuer in accordance with the requirements of the Securities Law and the relevant provisions of Reporting Rules No. 12, following the recognized business standards, ethical norms, and due diligence spirit of the Chinese legal profession. The legal opinions are as follows:
Inquiry Letter Question 1
According to the application documents, the Company is a comprehensive service provider of aviation material solutions integrating research and development, production, and sales, focusing on aviation material distribution, domestic PMA component research and airworthiness certification. The Company's main products are divided into distributed products and self-developed products. During the reporting period, the Company's operating revenues were RMB 825.68 million, RMB 909.36 million, and RMB 1.21679 billion, with net profits attributable to the parent company of RMB 89.62 million, RMB 84.86 million, and RMB 180.75 million, respectively. The gross profit margins of the Company's main business were 24.37%, 27.96%, and 29.06%, showing a year-on-year increase. The net cash flow from operating activities was RMB 4.61 million, RMB 46.31 million, and RMB 221.28 million, respectively.