Legal Opinion from Beijing Qizhi (Jinan) Law Firm
To: Shandong Xintong Electronics Co., Ltd.
Beijing Qizhi (Jinan) Law Firm (hereinafter referred to as "this firm") has been entrusted by your company to appoint lawyers Li Ying and Liu Fuqing (hereinafter referred to as "the lawyers of this firm") to attend your company's 2025 Annual Shareholders' Meeting (hereinafter referred to as "this shareholders' meeting" or "the meeting") and to issue this legal opinion in accordance with the Company Law of the People's Republic of China (hereinafter referred to as "the Company Law"), the Rules for Shareholders' Meetings of Listed Companies, and the Self-Regulatory Guidelines No. 1 for Main Board Listed Companies of the Shenzhen Stock Exchange, as well as relevant laws, regulations, normative documents, and the Articles of Association of Shandong Xintong Electronics Co., Ltd. (hereinafter referred to as "the Articles of Association").
This legal opinion only expresses views on the legality and validity of the convening and holding procedures of this shareholders' meeting, the qualifications of the convener and attendees, the voting procedures, and the voting results, and does not comment on the content of the proposals discussed at this shareholders' meeting or the authenticity and accuracy of the facts or data presented.
To issue this legal opinion, the lawyers of this firm reviewed the relevant matters concerning your company's shareholders' meeting, examined the "Notice of the 2025 Annual Shareholders' Meeting of Shandong Xintong Electronics Co., Ltd." (hereinafter referred to as "the 2025 Annual Shareholders' Meeting Notice"), the announcement of the resolution of the second meeting of the fifth board of directors, and the list of major shareholders provided by the Shenzhen Branch of China Securities Depository and Clearing Corporation Limited as of the close of trading on the equity registration date of May 19, 2026, among other relevant documents for this shareholders' meeting. The lawyers attended the meeting, conducted necessary verification and validation of relevant matters, witnessed the convening of the meeting, and participated in the on-site counting and monitoring of the voting ballots.
Your company has assured and committed to this firm and the lawyers that it has provided true original written materials or copies necessary for issuing this legal opinion, that the copies provided are consistent with the originals, and that the documents and statements made are true, accurate, and complete. All signatures and seals on the documents are genuine, and there are no false records, misleading statements, or significant omissions.
The lawyers of this firm, in accordance with the Securities Law, the Administrative Measures for Law Firms Engaging in Securities Legal Business, and the Practice Rules for Securities Legal Business of Law Firms, have strictly fulfilled their statutory duties, adhered to the principles of diligence and good faith, conducted thorough verification, and ensured that the facts recognized in this legal opinion are true, accurate, and complete, and that the conclusive opinions expressed are legal and accurate, with no false records, misleading statements, or significant omissions, and bear corresponding legal responsibilities.
The lawyers of this firm agree to use this legal opinion as part of your company's announcement materials for this shareholders' meeting, to be published along with other meeting documents, and to assume corresponding responsibilities based on this legal opinion.
The lawyers of this firm have issued the following legal opinions on the relevant legal matters of your company's shareholders' meeting in accordance with recognized business standards, ethical norms, and the spirit of diligence and good faith: