002236SZSE

Beijing Guofeng Law Firm's legal opinion on Zhejiang Dahua Technology Co., Ltd.'s 2026 employee stock ownership plan

✨ AI Summary

Beijing Guofeng Law Firm issued a legal opinion regarding Zhejiang Dahua Technology Co., Ltd.'s 2026 Employee Stock Ownership Plan (ESOP). The opinion confirms that Dahua is legally qualified to implement the ESOP and that the plan complies with relevant laws and regulations. The plan was approved by Dahua's board of directors on April 17, 2026, ensuring voluntary participation from employees and adherence to disclosure requirements.

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Beijing Guofeng Law Firm

About Zhejiang Dahua Technology Co., Ltd

The 2026 employee stock ownership plan

Legal opinion

Guofeng Lu Zheng Zi [2026] AN048-1

GRANDWAY

Grandway Law Offices

7th and 8th Floors, News Building, No. 26 Jianguomen Inner Street, Dongcheng District, Beijing Zip Code: 100005

Tel: 010-88004488/66090088 Fax: 010-66090016

Definition

In this legal opinion, unless the context otherwise requires, the following words or abbreviations have the following meanings:

Dahua Co., Ltd. refers to Zhejiang Dahua Technology Co., Ltd "Employee Stock Ownership Plan (Draft)" refers to the "Zhejiang Dahua Technology Co., Ltd. 2026 Employee Stock Ownership Plan (Draft)" "Measures for the Administration of Stock Ownership Plans" refers to the "Measures for the Administration of the 2026 Employee Stock Ownership Plan of Zhejiang Dahua Technology Co., Ltd." This employee stock ownership plan/stock ownership plan refers to the 2026 employee stock ownership plan to be implemented by Dahua Co., Ltd Holder/Participant means the employee of the company who has invested in the Share Ownership Scheme Underlying Stock refers to the A-share ordinary shares of Dahua Co., Ltd. to be held by the Stock Ownership Plan "Articles of Association" refers to the "Articles of Association of Zhejiang Dahua Technology Co., Ltd." Company Law means the Company Law of the People's Republic of China "Securities Law" means the Securities Law of the People's Republic of China "Pilot Guiding Opinions" refers to the "Guiding Opinions on the Pilot Implementation of Employee Stock Ownership Plans by Listed Companies (Revised in 2025)" Self-Regulatory Guidelines No. 1 refers to the Self-Regulatory Guidelines for Listed Companies on the Shenzhen Stock Exchange No. 1 - Standardized Operation of Listed Companies on the Main Board (Revised in 2025) China Securities Regulatory Commission refers to the China Securities Regulatory Commission Shenzhen Stock Exchange refers to the Shenzhen Stock Exchange The firm refers to Beijing Guofeng Law Firm Yuan and 10,000 yuan refer to RMB and 10,000 yuan

Note: If there is a discrepancy between the sum of the total number and the sum of the sub-values in this legal opinion, it is caused by rounding.

Beijing Guofeng Law Firm

About Zhejiang Dahua Technology Co., Ltd

2026 Employee Stock Ownership Plan

Legal Opinion

Guofeng Lu Zheng Zi [2026] AN048-1

To: Zhejiang Dahua Technology Co., Ltd

According to the Lawyer Service Agreement signed between the Firm and Dahua Co., Ltd., the Firm acted as the special legal counsel for the Company's employee stock ownership plan.

Our lawyers issue this legal opinion in accordance with the Company Law, the Securities Law, the Pilot Guiding Opinions, the Self-Regulatory Guidelines No. 1 and other laws, regulations and normative documents, as well as the relevant provisions of the China Securities Regulatory Commission and the Shenzhen Stock Exchange, in accordance with the recognized business standards, ethics and diligence of the lawyer industry.

In response to the issuance of this legal opinion, our lawyers make the following statement:

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