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 2026 Second Extraordinary 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 the General Meeting of Shareholders of Listed Companies," 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, lawyers appointed by the Firm attended the Meeting. The Firm's lawyers witnessed the entire process of the Meeting and conducted verification and confirmation of the documents and facts related to the Meeting.
The Firm agrees that this Legal Opinion may be disclosed to the public along with other documents that should be announced as part of the Company's shareholder meeting announcement, and the Firm shall bear legal responsibility for the legal opinions issued by its lawyers.
In accordance with the relevant provisions of the "Company Law," the "Rules for the General Meeting of Shareholders of Listed Companies," and the "Articles of Association," and adhering to the public standards, ethical norms, and diligent and responsible spirit of the legal profession, the Firm hereby issues the following legal opinion on the Meeting:
I. Regarding the Convening and Holding Procedures of the Meeting
On June 5, 2026, the Company's Eighth Board of Directors held its fifth meeting, deciding to convene the Meeting on June 22, 2026.
On June 6, 2026, the Company published the "Notice of COSCO SHIPPING Technology Co., Ltd. on Convening the 2026 Second Extraordinary General Meeting" on the CNINFO website (http://www.cninfo.com.cn) and in the "Securities Times," specifying the convener, method, time, venue, share registration date, attendees, matters to be deliberated, registration method for the on-site meeting, and identity verification for online voting.
On the afternoon of June 22, 2026, at 15:00, the on-site meeting was held as scheduled. The meeting was presided over by Mr. Wang Xinbo, Chairman of the Company, and the Firm's lawyers were present to witness the entire process.
Upon verification by the Firm's lawyers, the actual time, location, and agenda of the on-site meeting were consistent with those stated in the meeting notice.
The Firm's lawyers have verified that the notice, convening, and holding procedures of the Meeting comply with the provisions of the "Company Law," the "Rules for the General Meeting of Shareholders of Listed Companies," 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 183,056,020 shares with voting rights, accounting for 49.2525% of the Company's total share capital. Some directors and senior management personnel attended or were present at the Meeting.