Legal Opinion on the Second Extraordinary Shareholders' Meeting of Guangdong Dongfang Zirconium Technology Co., Ltd. in 2026
Guangdong Dongfang Zirconium Technology Co., Ltd.:
According to the requirements of the "Rules for Shareholders' Meetings of Listed Companies" issued by the China Securities Regulatory Commission (hereinafter referred to as the "Shareholders' Meeting Rules"), Guohao Law Firm (Guangzhou) (hereinafter referred to as "this firm") has been 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 "the lawyers of this firm") to attend Dongfang Zirconium's second extraordinary shareholders' meeting in 2026 (hereinafter referred to as "this meeting") and to issue legal opinions on important matters such as the convening and holding procedures of this meeting, the qualifications of attendees and conveners, voting procedures, and voting results.
This firm and the lawyers have strictly fulfilled their statutory duties in accordance with the "Company Law of the People's Republic of China" (hereinafter referred to as the "Company Law"), the "Management Measures for Law Firms Engaging in Securities Legal Business," and the "Practice Rules for Securities Legal Business of Law Firms (Trial)" and other regulations, as well as the facts that have occurred or existed prior to the issuance date of this legal opinion. They have adhered to the principles of diligence and good faith, conducted thorough verification, and ensured that the facts recognized in this legal opinion are true, accurate, and complete, and that the conclusions drawn are legal and accurate, with no false records, misleading statements, or significant omissions, and bear corresponding legal responsibilities.
I. Convening and Holding of This Shareholders' Meeting
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Convening of This Shareholders' Meeting
This shareholders' meeting was convened by the board of directors of Dongfang Zirconium based on the resolution of the sixth meeting of the ninth board of directors held on May 15, 2026. The board of directors of Dongfang Zirconium published the "Notice of the Second Extraordinary Shareholders' Meeting of Guangdong Dongfang Zirconium Technology Co., Ltd." on May 16, 2026, on the Giant Tide Information Network and other relevant websites and media, announcing the time and place of the meeting, the matters to be reviewed, the qualifications of attendees, and registration matters within the statutory period. The lawyers of this firm believe that the convenor and convening procedures of this shareholders' meeting comply with the "Company Law," "Shareholders' Meeting Rules," "Self-Regulatory Guidelines No. 1 for Listed Companies on the Shenzhen Stock Exchange - Standardized Operations of Main Board Listed Companies" (hereinafter referred to as the "Standardized Operations Guidelines"), "Implementation Rules for Online Voting at Shareholders' Meetings of Listed Companies on the Shenzhen Stock Exchange" (hereinafter referred to as the "Online Voting Implementation Rules"), and the relevant provisions of the articles of association of Dongfang Zirconium. -
Holding of This Shareholders' Meeting
This shareholders' meeting was held in a combined manner of on-site voting and online voting according to relevant regulations. The on-site meeting was held at 3:00 PM on June 1, 2026, in the conference room of the Dongfang Zirconium Park Comprehensive Building, located on Dingyang Road North, Yanhong Town, Chenghai District, Shantou City. The online voting for this shareholders' meeting was conducted through the trading system of the Shenzhen Stock Exchange and the internet voting system. The time for online voting through the Shenzhen Stock Exchange trading system was from 9:15 to 9:25, 9:30 to 11:30, and 13:00 to 15:00 on June 1, 2026; the time for online voting through the internet voting system was any time during the period from 9:15 to 15:00 on June 1, 2026. Directors and senior management of Dongfang Zirconium attended or were present at this shareholders' meeting. The lawyers of this firm believe that the holding procedures of this shareholders' meeting comply with the "Company Law," "Shareholders' Meeting Rules," "Standardized Operations Guidelines," "Online Voting Implementation Rules," and the relevant provisions of the articles of association of Dongfang Zirconium.