Legal Opinion on the 2021 Annual General Meeting of Shareholders of Xinguang Yuancheng Co., Ltd.

Legal Opinion on the 2021 Annual General Meeting of Shareholders of Xinguang Yuancheng Co., Ltd.

Shanghai Fengjin Lihe Law Firm (hereinafter referred to as "this firm") has been entrusted by Xinguang Yuancheng Co., Ltd. (hereinafter referred to as "the Company" or "Xinguang Yuancheng") to issue a legal opinion regarding the Company's 2021 Annual General Meeting of Shareholders (hereinafter referred to as "this meeting"), which was held on May 26, 2022 (conducted via video due to the COVID-19 pandemic).

This legal opinion is issued in accordance with 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 issued by the China Securities Regulatory Commission (hereinafter referred to as "the Shareholders' Meeting Rules"), and the Implementation Rules for Online Voting at Shareholders' Meetings issued by the Shenzhen Stock Exchange (hereinafter referred to as "the Online Voting Implementation Rules"), as well as the Company's Articles of Association and the Rules for Procedures of Shareholders' Meetings.

To issue this legal opinion, the lawyers of this firm declare:

1. This firm and the handling lawyers have strictly fulfilled their statutory duties and conducted sufficient verification of facts that occurred or existed prior to the issuance date of this legal opinion, ensuring that the facts recognized in this legal opinion are true, accurate, and complete, and that the conclusions drawn are lawful and accurate, without any false records, misleading statements, or significant omissions, and bear corresponding legal responsibilities.
2. The authenticity and validity of the identification documents, business licenses, power of attorney, stock account cards, and other materials presented by shareholders (agents) attending the meeting shall be the responsibility of the attending shareholders (agents). The responsibility of this firm's lawyers is to verify whether the names (or titles) of the attending shareholders and their shareholdings are consistent with the records provided by the Shenzhen Branch of China Securities Depository and Clearing Corporation Limited.
3. The qualifications of shareholders voting through the Shenzhen Stock Exchange trading system and the internet voting system are verified by Shenzhen Securities Information Co., Ltd. The voting actions of shareholders through these systems are considered as genuine expressions of their voting rights, and shareholders shall bear the corresponding legal consequences.
4. This firm agrees to include this legal opinion as a public announcement document for the Company's shareholders' meeting, to be disclosed to the public along with other documents that should be announced.

Based on the above declarations, the lawyers of this firm attended the on-site meeting of this meeting and witnessed the entire process of the meeting. According to the recognized business standards, ethical norms, and diligent spirit of the legal profession, and in accordance with the requirements of the Shareholders' Meeting Rules and the Company's Articles of Association, the lawyers of this firm provide the following legal opinions regarding the convening and holding procedures of this meeting, the qualifications of the convener and attendees, the voting procedures, and the voting results: