Zhong Lun Law Firm's Supplementary Legal Opinion II on Runbei Aviation Technology Co., Ltd.'s Issuance of Convertible Corporate Bonds to Undetermined Targets
To: Runbei Aviation Technology Co., Ltd.
Pursuant to the "Special Legal Services Agreement" signed between Runbei Aviation Technology Co., Ltd. (hereinafter referred to as the "Issuer" or the "Company") and Beijing Zhong Lun Law Firm (hereinafter referred to as the "Firm"), the Firm was entrusted by the Company to serve as the special legal advisor for the Company's issuance of convertible corporate bonds to undetermined targets (hereinafter referred to as the "Current Issuance").
In accordance with the "Company Law," "Securities Law," "Measures for the Administration of Securities Legal Business," "Practice Rules for Securities Legal Business," "Measures for the Administration of Registration," "Reporting Rule No. 12," and other laws, regulations, normative documents, and relevant regulations of the China Securities Regulatory Commission and the stock exchanges, the Firm has issued the "Legal Opinion of Beijing Zhong Lun Law Firm on Runbei Aviation Technology Co., Ltd.'s Issuance of Convertible Corporate Bonds to Undetermined Targets," the "First Supplementary Legal Opinion of Beijing Zhong Lun Law Firm on Runbei Aviation Technology Co., Ltd.'s Issuance of Convertible Corporate Bonds to Undetermined Targets" (collectively referred to as the "Original Legal Opinions"), and the "Lawyer's Work Report of Beijing Zhong Lun Law Firm on Runbei Aviation Technology Co., Ltd.'s Issuance of Convertible Corporate Bonds to Undetermined Targets" (hereinafter referred to as the "Lawyer's Work Report").
In accordance with the requirements of the "Second Round of Inquiry Letter on the Application for Issuance of Convertible Corporate Bonds by Runbei Aviation Technology Co., Ltd." (hereinafter referred to as the "Inquiry Letter II") issued by the Listing Review Center of the Shenzhen Stock Exchange on July 16, 2026 (No. 120039), and considering that the Issuer's board of directors approved the relevant proposals for the adjustment of the current issuance plan at the 27th meeting of the second board of directors held on June 15, 2026, and that the third extraordinary general meeting of shareholders and the first meeting of the third board of directors held on July 23, 2026, approved the relevant proposals for the election of the Company's directors and senior management, the Firm has conducted supplementary investigations into the aforementioned matters and issued this legal opinion.
This legal opinion constitutes a supplement to the Original Legal Opinions and the Lawyer's Work Report. Unless otherwise specified, the terms, names, abbreviations, etc., used in this legal opinion have the same meanings as in the Original Legal Opinions and the Lawyer's Work Report. All statements made by the Firm in the Original Legal Opinions and the Lawyer's Work Report apply to this legal opinion.
In accordance with the requirements of the "Securities Law" and the relevant provisions of "Reporting Rule No. 12," and in accordance with the generally accepted business standards, ethical norms, and the spirit of diligence and conscientiousness of the Chinese legal profession, the Firm has investigated and verified the documents provided by the Issuer and relevant facts, and hereby issues the following legal opinion:
PART ONE: RESPONSE TO "INQUIRY LETTER II"
I. Question 1 of "Inquiry Letter II"
According to the application documents and the response to the first round of inquiries, the Company's operating revenue mainly comes from the distribution of products and self-developed products. Among them, distributed products mainly include aviation fuel, aviation raw materials, and other consumable parts, while self-developed products mainly include high-molecular materials, tape and film materials, aviation electrical components, passenger/cargo compartment components, fine chemical products, and testing instruments.