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Grandall Law Firm (Guangzhou) Legal Opinion on the 2025 Annual Shareholders' Meeting of Guangdong Dongfang Zirconium Technology Co., Ltd.

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This legal opinion confirms the legality and validity of the 2025 Annual Shareholders' Meeting of Guangdong Dongfang Zirconium Technology Co., Ltd. It verifies the meeting's convening and holding procedures, the qualifications of attendees, and the voting procedures and results. All resolutions were passed in accordance with relevant laws and regulations.

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Legal Opinion on the 2025 Annual Shareholders' Meeting of Guangdong Dongfang Zirconium Technology Co., Ltd.

To Guangdong Dongfang Zirconium Technology Co., Ltd.:

Pursuant to the "Rules of the General Meeting of Shareholders of Listed Companies" issued by the China Securities Regulatory Commission (hereinafter referred to as the "Shareholders' Meeting Rules"), Grandall Law Firm (Guangzhou) (hereinafter referred to as the "Firm") was entrusted by Guangdong Dongfang Zirconium Technology Co., Ltd. (hereinafter referred to as "Dongfang Zirconium") to appoint lawyers Li Caixia and Li Shasha (hereinafter referred to as "Firm Lawyers") to attend Dongfang Zirconium's 2025 Annual Shareholders' Meeting (hereinafter referred to as the "Shareholders' Meeting") and issue a legal opinion on important matters such as the convening and holding procedures of the Shareholders' Meeting, the qualifications of attendees and the convener, and the voting procedures and results.

The Firm and its lawyers, in accordance with the "Company Law of the People's Republic of China" (hereinafter referred to as the "Company Law"), the "Administrative Measures for Law Firms Engaging in Securities Legal Business," and the "Practice Rules for Law Firms Engaging in Securities Legal Business (Trial)," and based on facts that have occurred or exist prior to the issuance of this legal opinion, have strictly performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough investigations and verifications, and ensured that the facts identified in this legal opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without any false records, misleading statements, or material omissions, and assume corresponding legal responsibilities.

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