Legal Opinion
To: Tianshui Huaten Technology Co., Ltd.
Beijing Jingtian Gongcheng Law Firm Shanghai Branch (hereinafter referred to as "this firm") is entrusted by Tianshui Huaten Technology Co., Ltd. (hereinafter referred to as "the Company") to issue this legal opinion (hereinafter referred to as "this legal opinion") regarding the legal matters involved in the convening, holding, voting procedures, qualifications of attendees, and valid voting of the Company's first extraordinary shareholders' meeting in 2026 (hereinafter referred to as "this shareholders' meeting"). This firm has issued this legal opinion in accordance with the "Company Law of the People's Republic of China," "Securities Law of the People's Republic of China," "Rules for Shareholders' Meetings of Listed Companies," and other current effective laws, regulations, normative documents, and the "Articles of Association of Tianshui Huaten Technology Co., Ltd." (hereinafter referred to as "the Articles of Association"), following the recognized business standards, ethical norms, and diligent and responsible spirit of the legal profession.
To issue this legal opinion, the lawyers of this firm reviewed the relevant documents and materials related to this shareholders' meeting and conducted necessary verification and validation regarding the convening, holding, voting procedures, qualifications of attendees, and valid voting rights. This firm only expresses legal opinions on the convening and holding procedures of this shareholders' meeting, the qualifications of attendees, voting procedures, and valid voting matters, and does not express opinions on the content of the proposals reviewed at this shareholders' meeting or the authenticity and accuracy of the facts and data involved in the proposals.
This firm and the handling lawyers have strictly fulfilled their statutory duties in accordance with the "Securities Law of the People's Republic of China," "Measures for the Administration of Securities Legal Business by Law Firms," and "Rules for the Practice of Securities Legal Business by Law Firms (Trial)," and have conducted sufficient verification and validation based on facts that occurred or existed before the issuance date of this legal opinion, ensuring that the facts recognized in this legal opinion are true, accurate, and complete, and that the conclusive opinions expressed are legal and accurate, without false records, misleading statements, or significant omissions, and bear corresponding legal responsibilities.
This legal opinion is only for the Company's use for this shareholders' meeting, and without prior written consent from this firm, the Company and any other legal entities, non-legal entities, or individuals shall not rely on, use, or quote this legal opinion for any other purpose. This firm agrees that this legal opinion can be disclosed to the public as part of the announcement materials for this shareholders' meeting, and bears relevant legal responsibilities in accordance with the law.
This firm provides the following opinions on the relevant legal issues regarding the convening and holding procedures, qualifications of attendees, voting procedures, and valid voting of this shareholders' meeting, in accordance with the recognized business standards, ethical norms, and diligent and responsible spirit of the legal profession:
I. Convening Procedures of this Shareholders' Meeting
On February 11, 2026, the Company published the "Notice of the First Extraordinary Shareholders' Meeting of Tianshui Huaten Technology Co., Ltd." on designated information disclosure media, notifying and announcing the method of convening this shareholders' meeting, meeting time, location, registration method, voting method, etc. Upon verification, the convening procedures of this shareholders' meeting comply with the provisions of laws, administrative regulations, and the Articles of Association.