Legal Opinion of Tian Yuan Law Firm on Beijing DaBeiNong Group Co., Ltd.'s 2025 Annual General Meeting
To: Beijing DaBeiNong Group Co., Ltd.
[Document Number: Jing Tian Gu Zi (2026) No. 320]
This legal opinion is issued by Tian Yuan Law Firm (hereinafter referred to as "the Firm") regarding the 2025 Annual General Meeting of Beijing DaBeiNong Group Co., Ltd. (hereinafter referred to as "the Company"). The meeting was held using a combination of on-site and online voting. The on-site meeting took place on May 15, 2026, at 14:30 in Conference Room 104, Administration Building, DaBeiNong Phoenix International Innovation Park, No. 19 Chengyuan Street, Haidian District, Beijing. The Firm was appointed by the Company to send lawyers to attend the on-site meeting. Based on the "Company Law of the People's Republic of China," the "Securities Law of the People's Republic of China" (hereinafter referred to as "Securities Law"), the "Rules for Shareholders' Meetings of Listed Companies" (hereinafter referred to as "Shareholders' Meeting Rules"), and the "Articles of Association of Beijing DaBeiNong Group Co., Ltd." (hereinafter referred to as "Articles of Association"), the Firm hereby issues this legal opinion on matters such as the convening and holding procedures, the qualifications of attendees, the convener's qualifications, the voting procedures, and the voting results of this shareholders' meeting.
To issue this legal opinion, the Firm's lawyers have reviewed the "Resolution Announcement of the Forty-Fifth Meeting of the Sixth Board of Directors of Beijing DaBeiNong Group Co., Ltd.," the "Notice of Beijing DaBeiNong Group Co., Ltd. on Convening the 2025 Annual General Meeting" (hereinafter referred to as "Notice of Convening Shareholders' Meeting"), and other documents and materials deemed necessary by the Firm's lawyers. Additionally, the Firm's lawyers have reviewed the identities and qualifications of shareholders attending the on-site meeting, witnessed the convening of the shareholders' meeting, and participated in the on-site counting and verification of votes for the proposals at the shareholders' meeting.
The Firm and its handling lawyers, in accordance with the "Securities Law," the "Administrative Measures for Securities Legal Business of Law Firms," and the "Practice Rules for Securities Legal Business of Law Firms (Trial)," and based on facts that have occurred or existed prior to the issuance date 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 determined in this legal opinion are true, accurate, and complete.
The Firm and its handling lawyers agree that this legal opinion will be used as a statutory document for the announcement of this shareholders' meeting, to be submitted to the Shenzhen Stock Exchange (hereinafter referred to as "SZSE") along with other announcement documents for review and public disclosure, and the Firm will bear legal responsibility for issuing this legal opinion.
The Firm's lawyers, in accordance with the generally accepted professional standards, ethical norms, and the spirit of diligence and conscientiousness in the legal profession, have investigated and verified the documents and relevant facts provided by the Company, and hereby issue the legal opinion as follows:
I. Convening and Holding Procedures of the Shareholders' Meeting
The Sixth Board of Directors of the Company resolved at its forty-fifth meeting held on April 22, 2026, to convene this shareholders' meeting. On April 24, 2026, the "Notice of Convening Shareholders' Meeting" was issued through designated information disclosure media. This "Notice of Convening Shareholders' Meeting" specified the time, place, matters to be deliberated, voting methods, and attendees of this shareholders' meeting.
This shareholders' meeting was held using a combination of on-site and online voting. The on-site meeting was held on May 15, 2026, at 14:30 in Conference Room 104, Administration Building, DaBeiNong Phoenix International Innovation Park, No. 19 Chengyuan Street, Haidian District, Beijing. The meeting was presided over by Ms. Mo Yun, the Chairperson, and all agenda items were completed.