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Legal Opinion on Shenzhen E-Tong Technology Co., Ltd.'s 2025 Annual General Meeting

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This legal opinion from DeHeng Law Offices reviews the 2025 Annual General Meeting of Shenzhen E-Tong Technology Co., Ltd. The meeting's convocation, procedures, attendee qualifications, and voting processes were found to comply with relevant laws and regulations. All resolutions passed were deemed legal and valid.

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DeHeng Law Offices

To: Shenzhen E-Tong Technology Co., Ltd.

Subject: Legal Opinion on Shenzhen E-Tong Technology Co., Ltd.'s 2025 Annual General Meeting

DeHeng 01G20240719-5

Shenzhen E-Tong Technology Co., Ltd. (hereinafter referred to as the "Company") held its 2025 Annual General Meeting (hereinafter referred to as the "Meeting") on May 18, 2026. DeHeng Law Offices (hereinafter referred to as "DeHeng"), commissioned by the Company, appointed lawyers He Qiuping and Zhao Yuting (hereinafter referred to as "DeHeng Lawyers") to attend the Meeting. 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"), and other relevant laws and regulations, as well as the Articles of Association of Shenzhen E-Tong Technology Co., Ltd. (hereinafter referred to as the "Articles of Association"), DeHeng Lawyers have witnessed the convocation, procedures, qualifications of attendees, and voting procedures of this Meeting and hereby issue their legal opinion.

To issue this legal opinion, DeHeng Lawyers attended the Meeting and reviewed the following documents provided by the Company, including but not limited to: (I) Articles of Association; (II) Rules of Procedure for Shareholders' Meetings of Shenzhen E-Tong Technology Co., Ltd.; (III) Resolution of the Third Meeting of the Seventh Board of Directors of Shenzhen E-Tong Technology Co., Ltd.; (IV) The "Notice of the 2025 Annual General Meeting of Shenzhen E-Tong Technology Co., Ltd." (hereinafter referred to as the "Notice of the Shareholders' Meeting") published by the Company on April 28, 2026, through designated information disclosure media; (V) On-site registration records and supporting documents of shareholders attending the Meeting; (VI) Voting records and supporting documents of shareholders for the Meeting; (VII) Other meeting documents for the Meeting.

DeHeng Lawyers have been assured that the Company has provided all materials deemed necessary by DeHeng Lawyers for issuing this legal opinion. The original materials, copies, and other documents provided, as well as oral statements, are true, accurate, and complete. The copies and originals of the materials are consistent.

In this legal opinion, DeHeng Lawyers, based on relevant laws and regulations and the Company's requirements, will only opine on whether the convocation and procedures of the Meeting comply with the provisions of laws, administrative regulations, and the Articles of Association, and whether the qualifications of the attendees and the convener are legal and valid, as well as the legality and validity of the voting procedures and results. DeHeng Lawyers will not opine on the content of the proposals deliberated at the Meeting or the truthfulness and accuracy of the facts or data stated in these proposals.

DeHeng and DeHeng Lawyers, in accordance with the Securities Law, the Administrative Measures for Lawyers Engaging in Securities Legal Business, the Practice Rules for Lawyers Engaging in Securities Legal Business (Trial), and other regulations, as well as facts that have occurred or existed prior to the issuance of this legal opinion, have diligently performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough investigations and verifications, and ensured that the facts determined in this legal opinion are true, accurate, and complete, and that the conclusions made are legal and accurate, without any false statements, misleading representations, or material omissions, and shall bear corresponding legal responsibilities.

This legal opinion is intended solely for the purpose of verifying the legality of the matters related to the Company's Meeting and shall not be used for any other purpose.

In accordance with the requirements of relevant laws and regulations, and in accordance with the generally accepted business standards, ethical norms, and the spirit of diligence and conscientiousness in the legal profession, DeHeng Lawyers hereby issue the following legal opinion on the legal issues concerning the convocation and procedures of the Company's Meeting:

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