TIANHE LAW OFFICE Legal Opinion
Anhui Tianhe Law Firm Legal Opinion on Hefei Urban Construction Development Co., Ltd.'s 2025 Annual General Meeting
Tianlvyi 2026 No. 01366
To: Hefei Urban Construction Development Co., Ltd.
In accordance with the "Securities Law of the People's Republic of China" (hereinafter referred to as the "Securities Law"), the "Company Law of the People's Republic of China" (hereinafter referred to as the "Company Law"), the "Rules for Shareholders' Meetings of Listed Companies," and the "Articles of Association of Hefei Urban Construction Development Co., Ltd." (hereinafter referred to as the "Articles of Association"), Anhui Tianhe Law Firm (hereinafter referred to as the "Firm") has been entrusted by Hefei Urban Construction Development Co., Ltd. (hereinafter referred to as "Hefei Urban Construction" or "the Company") to issue this legal opinion on the 2025 Annual General Meeting of Shareholders of Hefei Urban Construction held on May 12, 2026 (hereinafter referred to as the "Meeting").
The Firm's lawyers, adhering to the recognized professional standards, ethical norms, and diligent and responsible spirit of the legal profession, participated in the Meeting and have reviewed and verified the relevant documents and facts provided by the Company. The legal opinion is hereby issued as follows:
I. Convening Procedures of the Meeting
The Meeting was convened by the Company's Board of Directors. On April 21, 2026, the Board of Directors published the "Notice of Hefei Urban Construction Development Co., Ltd. on Convening the 2025 Annual General Meeting of Shareholders" in the Securities Times, China Securities Journal, Shanghai Securities News, Securities Daily, and on the Juchao Information Network.
The Firm's lawyers are of the opinion that the convening procedures of the Meeting comply with the provisions of laws, regulations, normative documents, and the Articles of Association.
II. Procedures for Holding the Meeting
The Meeting was held as scheduled on May 12, 2026, at 3:00 PM. The meeting was presided over by Mr. Song Derun, Chairman of the Company. The actual time, location, and content of the meeting were consistent with the announcement.
The Company provided an online voting platform for shareholders through the Shenzhen Stock Exchange trading system and the internet voting system. The voting period for the Shenzhen Stock Exchange trading system voting platform was from 9:15 AM to 9:25 AM, 9:30 AM to 11:30 AM, and 1:00 PM to 3:00 PM on May 12, 2026. The voting period for the Shenzhen Stock Exchange internet voting system was from 9:15 AM to 3:00 PM on May 12, 2026, which is consistent with the announcement.
Upon verification, the Firm's lawyers are of the opinion that the procedures for holding the Meeting comply with the provisions of laws, regulations, normative documents, and the Articles of Association.
III. Qualifications of Meeting Attendees
Upon inspection, a total of 505 shareholders, shareholder representatives, and circulating shareholders who voted online attended the Meeting, holding 482,017,343 shares with voting rights, accounting for 60.0053% of the Company's total share capital.
A total of 2 shareholders and shareholder representatives attended the Meeting in person, representing 476,701,159 shares, accounting for 59.3435% of the Company's total share capital. Upon verification, the qualifications of the shareholders and shareholder representatives comply with the provisions of the "Company Law," "Securities Law," and the "Articles of Association," and they are entitled to deliberate and vote on the proposals of the Meeting.
According to data provided by Shenzhen Securities Information Co., Ltd., a total of 503 circulating shareholders voted directly through the online system within the effective period, holding 5,316,184 shares with voting rights, accounting for 0.6618% of the Company's total share capital.
A total of 503 minority shareholders voted in person and online, holding 5,316,184 shares with voting rights, accounting for 0.6618% of the Company's total share capital.