Legal Opinion of Grandall Law Firm (Beijing) on Marco Polo Holdings Limited's 2025 Annual Shareholders Meeting
Grandall Law Firm (Beijing)
9th Floor, Taikang Financial Tower, No. 38 North Road East Third Ring, Chaoyang District, Beijing, 100026, China
Tel: 010-65890699
Fax: 010-65176800
Website: http://www.grandall.com.cn
May 2026
Legal Opinion
To: Marco Polo Holdings Limited
Grandall Law Firm (Beijing) has been entrusted by Marco Polo Holdings Limited (hereinafter referred to as "the Company" or "Marco Polo") to appoint lawyers to attend and witness the Company's 2025 Annual Shareholders Meeting held on May 22, 2026 (hereinafter referred to as "this Shareholders Meeting"), and to issue this legal opinion in accordance with the Securities Law of the People's Republic of China (hereinafter referred to as "the Securities Law"), the Company Law of the People's Republic of China (hereinafter referred to as "the Company Law"), and the Articles of Association of Marco Polo Holdings Limited (hereinafter referred to as "the Articles of Association"). Our lawyers agree to publish this legal opinion as a necessary document for the Company's Shareholders Meeting and assume legal responsibility for the opinions provided herein. There are no false or misleading statements or significant omissions in this legal opinion; otherwise, our lawyers are willing to bear corresponding legal responsibilities. Our lawyers have verified and validated the relevant documents and matters provided by the Company in accordance with recognized business standards, ethical norms, and the spirit of diligence and responsibility. The legal opinions are as follows:
I. Procedures for Convening and Holding the Shareholders Meeting
- Convening of the Shareholders Meeting
Our lawyers have verified that the convening of this Shareholders Meeting was proposed at the 16th meeting of the Company's second board of directors held on April 27, 2026. The board of directors is responsible for convening the meeting. According to the notice of the 2025 Annual Shareholders Meeting published on April 29, 2026, in designated disclosure media (hereinafter referred to as "the Meeting Notice"), the board of directors notified all shareholders 20 days prior to the meeting by announcement and disclosed the time, place, method of convening, record date, attendees, agenda items, and registration methods for the meeting.