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Grandall Law Firm (Guangzhou)
Legal Opinion on the 2026 Issuance of Shares to Specific Targets by Guangdong Orient Zirconic Ind Sci & Tech Co., Ltd.
To: Guangdong Orient Zirconic Ind Sci & Tech Co., Ltd.
Introduction
I. Basis for Issuing this Legal Opinion
(1) In accordance with the "Special Legal Counsel Engagement Contract" entered into between Guangdong Orient Zirconic Ind Sci & Tech Co., Ltd. (hereinafter referred to as the "Issuer") and this firm, this firm has appointed lawyers Li Caixia and Li Shasha (hereinafter referred to as "the Firm's Lawyers") to serve as special legal counsel for the Issuer's 2026 issuance of shares to specific targets (hereinafter referred to as "this Issuance of Shares"), to participate in relevant work and issue this legal opinion.
(2) The Firm's Lawyers have issued this legal opinion in accordance with the Company Law, the Securities Law, and other relevant laws, regulations, and the China Securities Regulatory Commission's "Administrative Measures for Issuance Registration," "Administrative Measures for Law Firms Engaging in Securities Legal Business," "Practice Rules for Law Firms in Securities Legal Business (Trial)," and other relevant provisions.
(3) The Firm's Lawyers have, in accordance with the requirements of the aforementioned laws, regulations, and normative documents, and following recognized professional standards, ethical norms, and a spirit of diligence and responsibility, verified the relevant documents and facts provided by the Issuer to issue this legal opinion.
II. Declarations
(1) This firm and the Firm's Lawyers have strictly performed their statutory duties in accordance with the Securities Law, the Administrative Measures for Law Firms Engaging in Securities Legal Business, the Practice Rules for Law Firms in Securities Legal Business (Trial), and other regulations, as well as facts that occurred or existed prior to the date of this legal opinion. We have followed the principles of diligence, responsibility, honesty, and trustworthiness, and have conducted sufficient verification to ensure that the facts recognized in this legal opinion are true, accurate, and complete, and that the conclusions reached are legal and accurate, without false records, misleading statements, or major omissions, and we assume corresponding legal liability.
(2) This firm consents to the use of this legal opinion and our "Lawyer's Work Report on the 2026 Issuance of Shares to Specific Targets by Guangdong Orient Zirconic Ind Sci & Tech Co., Ltd." (hereinafter referred to as the "Lawyer's Work Report") as necessary legal documents for the Issuer's application for this Issuance of Shares, to be submitted along with other application materials.
(3) This firm consents to the Issuer citing the content of this legal opinion or the Lawyer's Work Report in its application documents for this Issuance of Shares, or as required by the China Securities Regulatory Commission for review. However, the Issuer shall not cause legal ambiguity or misinterpretation when citing such content, and the Firm's Lawyers will review and confirm the content of the application documents for this Issuance of Shares again.
(4) The Firm's Lawyers have received the following guarantees from the Issuer: The Issuer has provided the original written materials, copies, or oral testimony that the Firm's Lawyers deem necessary for issuing this legal opinion and the Lawyer's Work Report. All signatures and seals on relevant materials are authentic, and all copies and duplicates are consistent with the originals. The Firm's Lawyers have reviewed these documents and confirmed that the copies are consistent with the originals. The Firm's Lawyers have issued this legal opinion and the Lawyer's Work Report based on the facts supported by these documents.
(5) For facts that are crucial to this legal opinion but cannot be supported by direct evidence, the Firm's Lawyers have relied on certification documents issued by the Issuer, relevant government departments, and other relevant units.