Beijing Xinghe Law Firm Legal Opinion
To: COSCO SHIPPING Technology Co., Ltd.
Beijing Xinghe Law Firm (hereinafter referred to as "the Firm") has been entrusted by COSCO SHIPPING Technology Co., Ltd. (hereinafter referred to as "the Company" or "the Company") to issue this legal opinion regarding the relevant matters of the Company's 2025 Annual General Meeting (hereinafter referred to as "the Meeting"). In accordance with the "Company Law of the People's Republic of China" (hereinafter referred to as "the Company Law"), the "Securities Law of the People's Republic of China" (hereinafter referred to as "the Securities Law"), the "Rules for Shareholders' Meetings of Listed Companies" (hereinafter referred to as "the Shareholders' Meeting Rules"), and the "Articles of Association of COSCO SHIPPING Technology Co., Ltd." (hereinafter referred to as "the Articles of Association"), the Firm hereby issues this legal opinion.
To prepare this legal opinion, the Firm appointed lawyers to attend the Meeting. The Firm's lawyers witnessed the entire process of the Meeting and conducted verification and validation of the documents and facts related to the Meeting.
The Firm's lawyers agree that this legal opinion may be disclosed to the public along with other documents that should be disclosed as part of the Company's announcement of the Meeting, and the Firm's lawyers shall bear legal responsibility for the legal opinions issued.
In accordance with the relevant provisions of the "Company Law," the "Shareholders' Meeting Rules," and the "Articles of Association," and in accordance with the public standards, ethical norms, and the spirit of diligence and responsibility of the legal profession, the Firm's lawyers hereby issue the following legal opinion on the Meeting:
I. Regarding the Convening and Holding Procedures of the Meeting
On March 26, 2026, the Company held its Eighth Board of Directors' Third Meeting, which resolved to convene the Meeting on April 17, 2026.
On March 28, 2026, the Company published the "Notice of the 2025 Annual General Meeting of COSCO SHIPPING Technology Co., Ltd." on the Juchao Information Network (http://www.cninfo.com.cn) and "Securities Times," which specified the convener, method, time, venue, stock registration date, attendees, matters for deliberation, registration method for on-site meetings, and identity verification and voting procedures for online voting.
On April 17, 2026, at 14:30, the on-site meeting was held as scheduled. The meeting was presided over by Mr. Wang Xinbo, Chairman of the Company. The Firm's lawyers attended and witnessed the entire process of the Meeting.
Upon verification by the Firm's lawyers, the actual time, location, and matters for deliberation of the Company's on-site meeting were consistent with the time, location, and matters specified in the announced meeting notice.
After verification, the Firm's lawyers are of the opinion that the notice, convening, and holding procedures of the Meeting comply with the provisions of the "Company Law," the "Shareholders' Meeting Rules," and the "Articles of Association."
II. Regarding the Qualifications of Attendees at the Meeting
The Meeting was held through a combination of on-site voting and online voting:
- According to the shareholder registration list provided by the Company, 38 shareholders or their representatives attended the on-site meeting, representing 183,037,520 shares with voting rights, accounting for 49.2475% of the Company's total share capital. Some directors and senior management personnel of the Company attended or were present at the Meeting.
Upon verification by the Firm's lawyers, the legal entity shareholder representatives attending the on-site meeting had obtained powers of attorney from the legal entity shareholders. Individual shareholders provided their identity documents and other relevant materials. The names/names of shareholders attending the Meeting and their shareholding amounts are consistent with the relevant information registered with the Shenzhen Branch of China Securities Depository and Clearing Corporation Limited as of the close of trading on April 9, 2026.