Grandway Law Offices Beijing Grandway Law Offices 7th and 8th Floors, Xinwen Building, 26 Jianguomennei Street, Dongcheng District, Beijing Tel: 010-88004488/66090088 Fax: 010-66090016 Postal Code: 100005 Beijing Grandway Law Offices Legal Opinion on Sichuan Development Long March Co., Ltd.'s 2026 First Extraordinary General Meeting Grandway Law Firm [2026] A0136 To: Sichuan Development Long March Co., Ltd. (the Company) Beijing Grandway Law Offices (the "Firm") has been retained by the Company to appoint lawyers to attend and witness the Company's 2026 First Extraordinary General Meeting (the "Meeting"). In accordance with the "Company Law of the People's Republic of China" (the "Company Law"), the "Securities Law of the People's Republic of China" (the "Securities Law"), the "Rules for Shareholders' Meetings of Listed Companies" (the "Shareholders' Meeting Rules"), the "Administrative Measures for Securities Legal Business of Law Firms" (the "Securities Legal Business Management Measures"), the "Practice Rules for Securities Legal Business of Law Firms (Trial)" (the "Securities Legal Business Practice Rules"), and other relevant laws, administrative regulations, rules, and normative documents, as well as the "Articles of Association of Sichuan Development Long March Co., Ltd." (the "Articles of Association"), the Firm's lawyers hereby issue this Legal Opinion regarding the procedures for convening and holding the Meeting, the qualifications of the convener, the qualifications of attendees, the voting procedures, and the voting results. The Firm's lawyers make the following statements regarding the issuance of this Legal Opinion:
- The Firm's lawyers shall only express opinions on the legality of the procedures for convening and holding the Meeting, the qualifications of the convener and on-site attendees, the voting procedures, and the voting results. Opinions will not be expressed on the content of the proposals deliberated at the Meeting or the truthfulness, accuracy, and completeness of the facts or data stated in such proposals.
- The Firm's lawyers are unable to witness the online voting process. The qualifications of shareholders participating in the online voting and the results of the online voting are certified by the relevant stock exchange trading system and the internet voting system.
- The Firm and its handling lawyers, in accordance with the "Securities Law," "Securities Legal Business Management Measures," "Securities Legal Business Practice Rules," and other regulations, and based on facts that have occurred or existed prior to the date of issuance of this Legal Opinion, have strictly performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough investigations and verifications, and ensured that the facts identified in this Legal Opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without any false records, misleading statements, or material omissions, and shall bear corresponding legal responsibilities.
- This Legal Opinion is for the sole purpose of the Company's Meeting and shall not be used for any other purpose. The Firm's lawyers agree to publish this Legal Opinion together with the Company's Meeting resolution. In accordance with the requirements of the "Company Law," "Securities Law," "Shareholders' Meeting Rules," "Securities Legal Business Management Measures," "Securities Legal Business Practice Rules," and other relevant laws, administrative regulations, rules, and normative documents, and in accordance with the generally accepted professional standards, ethical norms, and the spirit of diligence and good faith in the legal profession, the Firm's lawyers have investigated and verified the relevant documents and matters provided by the Company, and hereby issue the following legal opinion: I. Procedures for Convening and Holding the Meeting (I) Convening of the Meeting Upon investigation, the Meeting was decided to be convened by the Company's eighteenth meeting of the seventh session of the Board of Directors and was convened by the Board of Directors. On March 28, 2026, the Company's Board of Directors publicly announced the "Notice of Sichuan Development Long March Co., Ltd. on Convening the 2026 First Extraordinary General Meeting" (the "Notice") on information disclosure platforms such as the "Shanghai Securities News" and the Shenzhen Stock Exchange website (http://www.szse.com.cn/). The Notice specified the time, place, method of convening, matters to be deliberated, eligible attendees, and registration methods for the Meeting. (II) Holding of the Meeting The Meeting was held through a combination of on-site voting and online voting. The on-site meeting was held as scheduled on April 24, 2026, at 14:30 in Conference Room 1, 15th Floor, Lingdi Global Financial Center, Tianfu 2nd Street, High-tech Zone, Chengdu City, Sichuan Province. Mr. Zhu Quanfang, Chairman of the Company, presided over the Meeting. The voting period for the Shenzhen Stock Exchange system was from 9:15-9:25, 9:30-11:30, and 13:00-15:00 on April 24, 2026. The voting period for the Shenzhen Stock Exchange internet voting system was at any time from 9:15 to 15:00 on April 24, 2026. Upon investigation, the time, place, method, and content of the Company's Meeting were consistent with the information contained in the Notice. In summary, the procedures for convening and holding the Company's Meeting comply with the provisions of laws, administrative regulations, rules, normative documents, the "Shareholders' Meeting Rules," and the "Articles of Association." II. Qualifications of the Convener and Attendees of the Meeting The convener of the Meeting was the Company's Board of Directors, which meets the qualification requirements for a convener stipulated by laws, administrative regulations, rules, normative documents, the "Shareholders' Meeting Rules," and the "Articles of Association." Based on the identity documents of the shareholders attending the on-site meeting, the voting statistics feedback from Shenzhen Securities Information Co., Ltd., and the shareholder register as of the record date for the Meeting, and after verification by the Company and the Firm's lawyers, a total of 1,205 shareholders (shareholder representatives) attended the Meeting through on-site and online voting, representing 847,909,626 shares, accounting for 44.9174% of the Company's total share capital. In addition to the Company's shareholders (shareholder representatives), attendees of the Meeting also included some of the Company's directors, senior management, and the Firm's handling lawyers. Upon investigation, the qualifications of the on-site attendees comply with the provisions of laws, administrative regulations, rules, normative documents, the "Shareholders' Meeting Rules," and the "Articles of Association," and are legal and valid. The qualifications of shareholders participating in online voting have been certified by the Shenzhen Stock Exchange trading system and the internet voting system. III. Voting Procedures and Results of the Meeting Upon investigation, the Meeting deliberated all proposals listed in the Company's announced meeting notice in accordance with the provisions of laws, administrative regulations, rules, normative documents, the "Shareholders' Meeting Rules," and the "Articles of Association." The voting results are as follows:
- Resolution passed on the "Proposal to Amend the Measures for the Administration of Raised Funds" In favor: 813,113,107 shares, accounting for 95.8962% of the total voting shares held by shareholders (shareholder representatives) attending the Meeting; Against: 9,536,049 shares, accounting for 1.1247% of the total voting shares held by shareholders (shareholder representatives) attending the Meeting; Abstain: 25,260,470 shares, accounting for 2.9791% of the total voting shares held by shareholders (shareholder representatives) attending the Meeting.
- Resolution passed on the "Proposal to Amend the Measures for the Administration of External Guarantees" In favor: 813,036,396 shares, accounting for 95.8872% of the total voting shares held by shareholders (shareholder representatives) attending the Meeting; Against: 9,618,160 shares, accounting for 1.1343% of the total voting shares held by shareholders (shareholder representatives) attending the Meeting; Abstain: 25,255,070 shares, accounting for 2.9785% of the total voting shares held by shareholders (shareholder representatives) attending the Meeting.
- Resolution passed on the "Proposal on the Credit Limit for Company and Subsidiaries in 2026" In favor: 819,897,356 shares, accounting for 96.6963% of the total voting shares held by shareholders (shareholder representatives) attending the Meeting; Against: 27,631,870 shares, accounting for 3.2588% of the total voting shares held by shareholders (shareholder representatives) attending the Meeting; Abstain: 380,400 shares, accounting for 0.0449% of the total voting shares held by shareholders (shareholder representatives) attending the Meeting.
- Resolution passed on the "Proposal on Providing Guarantees for Financing of Shareholding Company Sichuan Development Tiansheng Mining Co., Ltd. and Related Party Transaction" In favor: 334,173,463 shares, accounting for 99.0333% of the total voting shares held by non-related shareholders (shareholder representatives) attending the Meeting; Against: 2,932,111 shares, accounting for 0.8689% of the total voting shares held by non-related shareholders (shareholder representatives) attending the Meeting; Abstain: 330,000 shares, accounting for 0.0978% of the total voting shares held by non-related shareholders (shareholder representatives) attending the Meeting. Sichuan Province Advanced Materials Industry Investment Group Co., Ltd., a related shareholder attending the meeting on-site, abstained from voting on this proposal. The Firm's lawyers and the shareholder representatives elected on-site were jointly responsible for counting and supervising the votes. The on-site voting slips were counted on the spot, and the final voting results were compiled and announced after being merged with the online voting results. Among them, the voting results of small and medium investors on relevant proposals were counted separately and disclosed separately. Upon investigation, proposals 1-3 were passed by more than half of the voting shares held by shareholders (shareholder representatives) attending the Meeting. Proposal 4 was passed by more than two-thirds of the voting shares held by non-related shareholders (shareholder representatives) attending the Meeting. In summary, the voting procedures and results of the Meeting comply with the provisions of laws, administrative regulations, rules, normative documents, the "Shareholders' Meeting Rules," and the "Articles of Association," and are legal and valid. IV. Conclusion In summary, the Firm's lawyers are of the opinion that the procedures for convening and holding the Company's Meeting comply with the provisions of laws, administrative regulations, rules, normative documents, the "Rules for Shareholders' Meetings of Listed Companies," and the "Articles of Association." The qualifications of the convener and attendees of the Meeting, as well as the voting procedures and results of the Meeting, are all legal and valid. This Legal Opinion is issued in duplicate. (This page is intentionally left blank, serving as the signature page for the "Legal Opinion of Beijing Grandway Law Offices on the 2026 First Extraordinary General Meeting of Sichuan Development Long March Co., Ltd.") Person in Charge: Zhang Liguo [blank] Beijing Grandway Law Offices Handling Lawyer: Xue Yuting [blank] Zhang Xiaowu [blank] 2026 April 24