ZHONG LUN Law Firm Special General Partnership Guangdong Shenzhen Futian District Yitian Road No. 5033 Ping An Finance Centre Tower A 57/58/59 Floor Postal Code: 518000 57/58/59/F, Tower A, Ping An Finance Centre, 5033 Yitian Road, Futian District, Shenzhen, Guangdong 518000, China Tel: +86 755 3325 6666 Fax: +86 755 3320 6888 www.zhonglun.com Shenzhen Zhong Lun Law Firm Regarding China Merchants Yu Industrial Operations Services Co., Ltd. Legal Opinion on the First Extraordinary General Meeting of 2026 To: China Merchants Yu Industrial Operations Services Co., Ltd. (the Company) Pursuant to the "Company Law of the People's Republic of China" (hereinafter referred to as the "Company Law"), the "Securities Law of the People's Republic of China" (hereinafter referred to as the "Securities Law"), the "Rules of Shareholders' Meetings of Listed Companies" issued by the China Securities Regulatory Commission (hereinafter referred to as the "Shareholders' Meeting Rules"), and the "Articles of Association of China Merchants Yu Industrial Operations Services Co., Ltd." (hereinafter referred to as the "Articles of Association"), Shenzhen Zhong Lun Law Firm (hereinafter referred to as the "Firm") was entrusted by the Company to send lawyers to attend the Company's First Extraordinary General Meeting of 2026 (hereinafter referred to as the "Meeting") to witness on-site the legality of the procedures for convening and holding the Meeting, the qualifications of attendees, the qualifications of the convener, the voting procedures, and the voting results, and to issue this legal opinion accordingly. The Firm's lawyers have received the following assurances from the Company: The Company has provided and disclosed all documents and all factual circumstances that the Firm's lawyers deem necessary for issuing this legal opinion. All documents and statements provided by the Company (including written and oral) are true, accurate, and complete, and the copies of documents provided are consistent with the originals. In this legal opinion, the Firm's lawyers will only express opinions on whether the convening and holding procedures, the qualifications of attendees, the qualifications of the convener, and the voting procedures and results of this Meeting comply with the provisions of the "Company Law", the "Shareholders' Meeting Rules", and the "Articles of Association". The Firm will not express opinions on the content of the proposals deliberated at this Meeting or the truthfulness and accuracy of the facts or data stated in these proposals. The Firm's lawyers, in accordance with the generally accepted professional standards, ethical norms, and the spirit of diligence and conscientiousness of the legal profession, hereby issue the following legal opinion on the relevant legal issues concerning the convening of this Meeting: I. Convening and Holding Procedures of the Meeting The Meeting was convened by the Company's Board of Directors. On April 3, 2026, the Company's Board of Directors published the "Notice of the First Extraordinary General Meeting of 2026 of China Merchants Yu Industrial Operations Services Co., Ltd." on the Juchao Information Network (www.cninfo.com.cn), announcing the basic information of the Meeting (Meeting session, convener, date, time, meeting method, share registration date, attendees, on-site meeting location), matters to be deliberated at the Meeting, meeting registration, and the specific operating procedures for online voting. The Meeting adopted a voting method combining on-site voting and online voting. The on-site meeting was held at 14:30 on April 21, 2026, in Meeting Room 1301, New Era Plaza, No. 1, Taizi Road, Wanghai Community, Nanshan District, Shenzhen. The online voting period was: April 21, 2026. Specifically, the online voting time through the Shenzhen Stock Exchange trading system was from 9:15 to 9:25 and 9:30 to 11:30 on April 21, 2026, and from 13:00 to 15:00; the online voting time through the Shenzhen Stock Exchange internet voting system was from 9:15 to 15:00 on April 21, 2026. Upon verification, the time, location, method, and content of the Meeting are consistent with the announcement. In summary, the convening and holding method of the Meeting complies with the relevant provisions of the "Company Law", the "Shareholders' Meeting Rules", and the "Articles of Association". II. Qualifications of the Convener and Attendees of the Meeting The Meeting was convened by the Company's Board of Directors, and one director was jointly nominated by more than half of the directors to preside. A total of 185 shareholders (or their authorized representatives) attended the on-site meeting and participated in online voting, representing 722,899,605 shares, accounting for 68.6045% of the total voting shares of the Company (this legal opinion retains four decimal places; any discrepancy is due to rounding). Of these, 3 shareholders and shareholder representatives attended the on-site meeting, representing 542,575,464 shares, accounting for 51.4914% of the total voting shares of the Company. According to the "Statistics of Online Voting Results for the First Extraordinary General Meeting of China Merchants Yu in 2026" obtained by the Company from Shenzhen Securities Information Co., Ltd., 182 shareholders participated in online voting through the Shenzhen Stock Exchange trading system and the Shenzhen Stock Exchange internet voting system, representing 180,324,141 shares, accounting for 17.1131% of the total voting shares. The qualifications of shareholders participating in online voting have been verified by the Shenzhen Stock Exchange trading system and the internet voting system. The Firm's lawyers cannot verify the qualifications of online voting shareholders. Provided that the qualifications of shareholders participating in online voting comply with the provisions of laws, administrative regulations, and normative documents and the "Articles of Association", the relevant attending shareholders are qualified. A total of 182 minority shareholders (minority shareholders refer to shareholders who, individually or collectively, hold less than 5% of the shares, excluding directors and senior management of the Company) attended the meeting, representing 60,421,352 shares, accounting for 5.7341% of the total voting shares of the Company. Some directors and senior management of the Company attended or were present at the Meeting. Upon verification, the qualifications of the convener and attendees of the Meeting comply with the relevant provisions of the "Company Law" and other laws, regulations, normative documents, and the "Articles of Association", and are legal and valid. III. Voting Procedures and Results of the Meeting (I) Upon verification, the matters deliberated at the Meeting are consistent with the matters listed in the announcement and notice, and no matters not listed in the announcement were deliberated and voted upon. (II) Upon verification, the Meeting voted by a combination of on-site registered voting and online voting. As there were fewer than two non-connected shareholders attending the on-site meeting, one non-connected shareholder representative and the Firm's lawyers were appointed to count and supervise the votes. The on-site votes were counted on the spot, and the final voting results were announced after being combined with the online voting results. (III) The deliberation of proposals at the Meeting is as follows:
- "Proposal on the Estimated Annual Related Party Transactions between China Merchants Group and its Subsidiaries in 2026" The overall voting result for this proposal was: 180,137,841 shares in favor, accounting for 99.8397% of the voting shares of attending shareholders and authorized representatives; 263,500 shares against, accounting for 0.1460% of the voting shares of attending shareholders and authorized representatives; and 25,800 shares abstained, accounting for 0.0143% of the voting shares of attending shareholders and authorized representatives. Among them, the voting situation of minority shareholders attending the meeting was: 60,132,052 shares in favor, accounting for 99.5212% of the voting shares of attending minority shareholders and authorized representatives; 263,500 shares against, accounting for 0.4361% of the voting shares of attending minority shareholders and authorized representatives; and 25,800 shares abstained, accounting for 0.0427% of the voting shares of attending minority shareholders and authorized representatives. Related shareholders abstained from voting on this proposal. Voting result: This matter was approved.
- "Proposal on Reducing Registered Capital and Amending the Articles of Association" The overall voting result for this proposal was: 722,589,901 shares in favor, accounting for 99.9572% of the voting shares of attending shareholders and authorized representatives; 282,704 shares against, accounting for 0.0391% of the voting shares of attending shareholders and authorized representatives; and 27,000 shares abstained, accounting for 0.0037% of the voting shares of attending shareholders and authorized representatives. Among them, the voting situation of minority shareholders attending the meeting was: 60,111,648 shares in favor, accounting for 99.4874% of the voting shares of attending minority shareholders and authorized representatives; 282,704 shares against, accounting for 0.4679% of the voting shares of attending minority shareholders and authorized representatives; and 27,000 shares abstained, accounting for 0.0447% of the voting shares of attending minority shareholders and authorized representatives. This proposal is a special resolution. Voting result: This matter was approved.
- "Proposal on Adding the Position of Vice Chairman and Amending the Articles of Association and their Appendices" The overall voting result for this proposal was: 722,424,601 shares in favor, accounting for 99.9343% of the voting shares of attending shareholders and authorized representatives; 448,704 shares against, accounting for 0.0621% of the voting shares of attending shareholders and authorized representatives; and 26,300 shares abstained, accounting for 0.0036% of the voting shares of attending shareholders and authorized representatives. Among them, the voting situation of minority shareholders attending the meeting was: 59,946,348 shares in favor, accounting for 99.2138% of the voting shares of attending minority shareholders and authorized representatives; 448,704 shares against, accounting for 0.7426% of the voting shares of attending minority shareholders and authorized representatives; and 26,300 shares abstained, accounting for 0.0435% of the voting shares of attending minority shareholders and authorized representatives. This proposal is a special resolution. Voting result: This matter was approved.
- "Proposal on Appointing Directors for the Eleventh Board of Directors" The overall voting result for this proposal was: 722,437,301 shares in favor, accounting for 99.9360% of the voting shares of attending shareholders and authorized representatives; 428,404 shares against, accounting for 0.0593% of the voting shares of attending shareholders and authorized representatives; and 33,900 shares abstained, accounting for 0.0047% of the voting shares of attending shareholders and authorized representatives. Among them, the voting situation of minority shareholders attending the meeting was: 59,959,048 shares in favor, accounting for 99.2349% of the voting shares of attending minority shareholders and authorized representatives; 428,404 shares against, accounting for 0.7090% of the voting shares of attending minority shareholders and authorized representatives; and 33,900 shares abstained, accounting for 0.0561% of the voting shares of attending minority shareholders and authorized representatives. Voting result for this proposal: This matter was approved.
- "Proposal on Concurrent Employment of Directors and General Manager" The overall voting result for this proposal was: 180,113,937 shares in favor, accounting for 99.8264% of the voting shares of attending shareholders and authorized representatives; 279,904 shares against, accounting for 0.1551% of the voting shares of attending shareholders and authorized representatives; and 33,300 shares abstained, accounting for 0.0185% of the voting shares of attending shareholders and authorized representatives. Among them, the voting situation of minority shareholders attending the meeting was: 60,108,148 shares in favor, accounting for 99.4816% of the voting shares of attending minority shareholders and authorized representatives; 279,904 shares against, accounting for 0.4633% of the voting shares of attending minority shareholders and authorized representatives; and 33,300 shares abstained, accounting for 0.0551% of the voting shares of attending minority shareholders and authorized representatives. Related shareholders abstained from voting on this proposal. Voting result: This matter was approved. In summary, the voting procedures and methods of this Meeting comply with the relevant provisions of the "Company Law", the "Shareholders' Meeting Rules", and the "Articles of Association", and the voting results are legal and valid. IV. Conclusion In summary, the Firm's lawyers are of the opinion that the convening and holding procedures of the Company's Meeting comply with the provisions of laws, regulations, normative documents, and the "Articles of Association", and that the qualifications of the Meeting's convener and attendees, as well as the voting procedures and results, are legal and valid. This legal opinion is made in four copies. (End of text) (This page is the signature page of the "Legal Opinion on the First Extraordinary General Meeting of 2026 of China Merchants Yu Industrial Operations Services Co., Ltd. by Shenzhen Zhong Lun Law Firm") Shenzhen Zhong Lun Law Firm (Seal) Person in Charge: Lai Wai Hung Handling Lawyer: Rao Xiaomin Handling Lawyer: Dai Yufang April 21, 2026