Beijing Qizhi (Jinan) Law Firm Legal Opinion
To: Shandong Xintong Electronics Co., Ltd.
Beijing Qizhi (Jinan) Law Firm (hereinafter referred to as "the Firm") was entrusted by your company to appoint lawyer Li Ying and lawyer Liu Fuqing (hereinafter referred to as "the Firm's lawyers") to attend your company's 2026 First Extraordinary General Meeting (hereinafter referred to as "the General Meeting" or "the Meeting"). Based on 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 "Normative Operation Guidelines for Main Board Listed Companies No. 1" issued by the Shenzhen Stock Exchange, as well as other laws, regulations, rules, normative documents, and the Articles of Association of Shandong Xintong Electronics Co., Ltd. (hereinafter referred to as "the Articles of Association"), this Legal Opinion is hereby issued.
This Legal Opinion only expresses opinions on the legality and validity of the procedures for convening and holding the General Meeting, the qualifications of the convener and attendees, and the voting procedures and results. It does not express opinions on the truthfulness and accuracy of the content of the proposals deliberated at the General Meeting or the facts and data contained therein.
To issue this Legal Opinion, the Firm's lawyers have reviewed the matters related to the General Meeting, examined the "Notice of Shandong Xintong Electronics Co., Ltd. on Convening the 2026 First Extraordinary General Meeting" (hereinafter referred to as "the Notice of the General Meeting"), the "Announcement of the Fourth Meeting of the Fifth Board of Directors," and the "List of Top N Security Holders" provided by China Securities Depository and Clearing Corporation Limited Shenzhen Branch as of the close of trading on June 16, 2026, the equity registration date. The Firm's lawyers attended the General Meeting, conducted necessary verification and validation of relevant matters, witnessed the convening of the General Meeting, and participated in the on-site counting and supervision of votes for the proposals of the General Meeting.
Your company has guaranteed and promised to the Firm and its lawyers that your company has provided all necessary, true, and original written materials or copies thereof for the issuance of this Legal Opinion, that the copies of the provided documents are identical to the originals, that the provided documents and statements are true, accurate, and complete, and that all signatures and seals on the documents are genuine, with no false records, misleading statements, or material omissions.
The Firm and its handling lawyers, in accordance with the "Securities Law," the "Measures for the Administration of Securities Legal Business of Law Firms," and the "Practice Rules for Securities Legal Business of Law Firms," and based on facts that have occurred or existed before the date of issuance of this Legal Opinion, have strictly performed their statutory duties, adhered to the principles of diligence, responsibility, and good faith, conducted thorough verification and validation, ensured that the facts identified in this Legal Opinion are true, accurate, and complete, and that the conclusions made are legal and accurate, with no false records, misleading statements, or material omissions, and shall bear corresponding legal responsibilities.
The Firm's lawyers agree that this Legal Opinion will be used as an announcement material for your company's General Meeting and will be published along with other meeting documents, and the Firm will bear corresponding responsibilities based on this Legal Opinion.
The Firm's lawyers, in accordance with the generally accepted business standards, ethical norms, and the spirit of diligence and responsibility of the legal profession, hereby provide the following legal opinion on the relevant legal matters of your company's General Meeting: