002388SZSE

Board of Directors' Special Opinion on the Independence of Independent Directors

Xinya Process Co., Ltd.·

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The Board of Directors of Xinya Process (Zhejiang) Co., Ltd. has assessed the independence of its current independent directors. The assessment confirms that the directors meet the requirements of relevant regulations regarding their professional experience and self-assessment. They hold no other positions within the company or its major shareholders and have no relationships that could impair their independent judgment.

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Board of Directors of Xinya Process (Zhejiang) Co., Ltd.

Special Opinion on the Independence of Independent Directors

In accordance with the "Administrative Measures for Independent Directors of Listed Companies," the "Stock Listing Rules of the Shenzhen Stock Exchange," and the "Shenzhen Stock Exchange Main Board Listed Company Self-Regulatory Management Guide No. 1 - Standardized Operation of Main Board Listed Companies," the Board of Directors of Xinya Process (Zhejiang) Co., Ltd. (hereinafter referred to as the "Company") has assessed the independence of its current independent directors, Zhai Zhisheng, Cui Huijun, and Yang Youmin, and hereby issues the following special opinion:

Upon review of the aforementioned independent directors' professional experience and signed self-assessment documents, it is confirmed that these individuals do not hold any positions within the Company other than that of independent director, nor do they hold any positions within the Company's major shareholder entities. They have no conflict of interest or other relationships with the Company and its major shareholders that could impair their ability to make independent and objective judgments. The independent directors of the Company comply with the requirements for the independence of independent directors stipulated in the "Administrative Measures for Independent Directors of Listed Companies" and the "Shenzhen Stock Exchange Main Board Listed Company Self-Regulatory Management Guide No. 1 - Standardized Operation of Main Board Listed Companies."

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