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Legal Opinion of Fujian Zenith Law Firm on the Adjustment and Grant of the 2026 Restricted Stock Incentive Plan of Kehua Data Co., Ltd.

KEHUA DATA CO.,LTD.·

✨ AI Summary

This legal opinion confirms that the adjustment and grant of Kehua Data's 2026 Restricted Stock Incentive Plan have received necessary approvals and authorizations. The adjustments to the grant price and number of shares comply with relevant regulations and the plan's provisions. The conditions for granting the restricted shares have been met, and the plan is proceeding as scheduled.

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Fujian Zenith Law Firm

Regarding the Legal Opinion on the Adjustment and Grant of the 2026 Restricted Stock Incentive Plan of Kehua Data Co., Ltd.

Min Li Fei Zi [2026] No. 070-01

To: Kehua Data Co., Ltd.

Fujian Zenith Law Firm (hereinafter referred to as "the Firm") has been legally engaged by Kehua Data Co., Ltd. (hereinafter referred to as "Kehua Data" or "the Company") to provide this legal opinion, 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 "Administrative Measures for Equity Incentives of Listed Companies" issued by the China Securities Regulatory Commission (hereinafter referred to as the "CSR C") (hereinafter referred to as the "Administrative Measures"), and other relevant laws, regulations, and normative documents. This legal opinion concerns the adjustment (hereinafter referred to as the "Adjustment") and grant (hereinafter referred to as the "Grant") of the Company's 2026 Restricted Stock Incentive Plan (hereinafter referred to as the "Incentive Plan") and is issued in accordance with the industry-recognized business standards, ethical norms, and the principle of diligence and conscientiousness.

The Firm hereby makes the following statements regarding this legal opinion:

  1. The Firm and the handling lawyers have fulfilled their statutory duties in strict accordance with the provisions of the effective laws, regulations, rules, and normative documents, including the "Securities Law," "Administrative Measures for Securities Legal Services of Law Firms," and "Practice Rules for Securities Legal Services of Law Firms (Trial)," and based on facts that have occurred or existed prior to the issuance of this legal opinion. We have adhered to the principles of diligence, conscientiousness, 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.

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