Allbright Law Offices
Legal Opinion
Shanghai Allbright Law Offices
Regarding Shandong Zhongrui Industrial Development Co., Ltd.'s
2026 Fourth Extraordinary General Meeting
To: Shandong Zhongrui Industrial Development Co., Ltd.
Shanghai Allbright Law Offices (hereinafter referred to as "the Firm") has been entrusted by Shandong Zhongrui Industrial Development Co., Ltd. (hereinafter referred to as "the Company") to issue this Legal Opinion regarding the relevant matters of the Company's 2026 Fourth Extraordinary General Meeting (hereinafter referred to as "this EGM"). In accordance with 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 other laws, regulations, rules, and normative documents, as well as the "Articles of Association of Shandong Zhongrui Industrial Development Co., Ltd." (hereinafter referred to as "the Articles of Association"), this Legal Opinion is hereby issued.
To issue this Legal Opinion, the Firm and its lawyers have strictly performed their statutory duties in accordance with the "Administrative Measures for Law Firms Engaging in Securities Legal Business" and the "Practice Rules for Securities Legal Business of Law Firms (Trial)," and have adhered to the principles of diligence and good faith. Necessary investigations and verifications have been conducted on the matters related to this EGM, relevant documents and materials that the Firm deems necessary for issuing this Legal Opinion have been reviewed, and the entire process of this EGM has been attended. The Firm guarantees that the facts identified in this Legal Opinion are true, accurate, and complete, and that the conclusions expressed are legal, accurate, and free from any false statements, misleading representations, or material omissions, and the Firm is willing to bear the corresponding legal responsibilities.
In view of the above, the Firm's lawyers, in accordance with the requirements of the aforementioned laws, regulations, rules, and normative documents, and following the generally accepted business standards, ethical norms, and spirit of diligence in the legal profession, hereby issue the following legal opinion:
I. Qualifications of the Convener and Procedures for Convening and Holding this EGM
(I) Convening of this EGM
Upon verification, this EGM was convened by the Company's Board of Directors. On July 23, 2026, the Company held its Seventh Board of Directors' Seventh Meeting, which resolved to convene this EGM. On July 24, 2026, the Company issued the "Notice of Shandong Zhongrui Industrial Development Co., Ltd. on Convening the 2026 Fourth Extraordinary General Meeting" in the "China Securities Journal," "Shanghai Securities News," "Securities Times," "Securities Daily," and on the Juchao Information Network (http://www.cninfo.com.cn). The meeting notice specified the convener, date and time of the EGM (including the date and time of the on-site meeting and online voting), the method of convening, the stock registration date, the attendees, the meeting location, the matters to be deliberated, the registration method for the on-site meeting, the operating procedures for online voting, and the contact person and contact information. The date of the announcement publication was more than 15 days prior to the convening date of this EGM.
(II) Holding of this EGM
The on-site meeting of this EGM was held as scheduled on August 10, 2026, at 14:00 at No. 767, Lane 2, Jinzhong Road, Changning District, Shanghai.