Legal Opinion from Shaanxi Jiaxuan Law Firm on the First Extraordinary Shareholders' Meeting of Xinjiang Zhongtai Chemical Co., Ltd. in 2026
To: Xinjiang Zhongtai Chemical Co., Ltd. (hereinafter referred to as "the Company")
Shaanxi Jiaxuan Law Firm (hereinafter referred to as "this Firm") has been entrusted by the Company to appoint lawyers to witness the legality of the Company's first extraordinary shareholders' meeting in 2026 (hereinafter referred to as "this Meeting" or "this Shareholders' Meeting"). Based on the provisions of 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 for Shareholders' Meetings of Listed Companies (hereinafter referred to as "the Meeting Rules"), and other current effective laws, administrative regulations, rules, normative documents, and the Articles of Association of Xinjiang Zhongtai Chemical Co., Ltd. (hereinafter referred to as "the Articles of Association"), this legal opinion is issued regarding the convening and holding procedures of this Meeting, the qualifications of the convener, the qualifications of attendees, the voting procedures, and the voting results.
To issue this legal opinion, the lawyers of this Firm have reviewed relevant documents in accordance with the requirements of the Company Law, the Meeting Rules, and the provisions of the Articles of Association, and have verified the legality and validity of the convening and holding procedures of the shareholders' meeting, the qualifications of attendees, the voting methods, and the voting procedures. This legal opinion is solely for the purpose of the Company's shareholders' meeting, and the lawyers of this Firm agree to announce this legal opinion as an essential legal document for the Company's shareholders' meeting and shall bear corresponding responsibilities in accordance with the law. The lawyers of this Firm express the following legal opinions regarding the authenticity, completeness, legality, and validity of the convening, holding procedures, qualifications of attendees, and voting procedures of this shareholders' meeting:
I. The Convening and Holding Procedures of this Meeting
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The convening of this Meeting was verified, and the Company's board of directors approved the proposal to convene the first extraordinary shareholders' meeting of 2026 on February 10, 2026, and publicly released the notice of the meeting on the Giant Tide Information Network (http://www.cninfo.com.cn) and in the Securities Times. The notice included the time, location, method of holding the meeting, matters for discussion, attendees, share registration date, and meeting registration method.
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The holding of this Meeting adopted a combination of on-site voting and online voting. The shareholders' meeting was held on schedule according to the content and method of the notice, presided over by Mr. Huang Xiaohu, the chairman of the Company, who reported on the proposals to be discussed at this meeting. The specific time for online voting through the Shenzhen Stock Exchange trading system was February 27, 2026, with the following time slots: 9:15-9:25, 9:30-11:30 in the morning, and 13:00-15:00 in the afternoon. The share registration date for this meeting was February 24, 2026 (Tuesday). In summary, the convening and holding procedures of this meeting comply with the provisions of laws, administrative regulations, rules, normative documents, the Meeting Rules, and the Articles of Association.