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Legal Opinion of King & Wood Mallesons on the 2025 Annual General Meeting of Zibo Qixiang Tengda Chemical Co., Ltd.

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This legal opinion confirms that the convening and holding procedures of Zibo Qixiang Tengda Chemical Co., Ltd.'s 2025 Annual General Meeting complied with relevant laws and regulations. The qualifications of attendees and the convener were valid. The voting procedures and results for all proposals, including the 2025 Annual Report and the 2026 credit application, were legal and effective.

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King & Wood Mallesons Beijing Office: 18th Floor, East Tower, World Financial Center, 1 Dongsanhuan Zhonglu, Chaoyang District, Beijing, 100020, PRC T +86 10 5878 5588 F +86 10 5878 5566 www.kingandwood.com

Beijing King & Wood Mallesons Legal Opinion on the 2025 Annual General Meeting of Zibo Qixiang Tengda Chemical Co., Ltd.

To: Zibo Qixiang Tengda Chemical Co., Ltd.

Beijing King & Wood Mallesons (hereinafter referred to as "the Firm") has been retained by Zibo Qixiang Tengda Chemical Co., Ltd. (hereinafter referred to as "the Company") to provide this legal opinion. Based on the currently effective laws, administrative regulations, rules, and normative documents of the People's Republic of China (including the Hong Kong Special Administrative Region, the Macao Special Administrative Region, and Taiwan Province of China) (hereinafter referred to as "China Mainland" for the purpose of this legal opinion only), including the Securities Law of the People's Republic of China (hereinafter referred to as the "Securities Law"), the Company Law of the People's Republic of China (hereinafter referred to as the "Company Law"), the Administrative Measures for Shareholders' Meetings of Listed Companies issued by the China Securities Regulatory Commission (hereinafter referred to as the "Shareholders' Meeting Rules"), and the relevant provisions of the Articles of Association of Zibo Qixiang Tengda Chemical Co., Ltd. (hereinafter referred to as the "Articles of Association"), the Firm has appointed lawyers to attend the 2025 Annual General Meeting of the Company held on May 8, 2026 (hereinafter referred to as the "Current Shareholders' Meeting") and hereby issues this legal opinion on matters related to the Current Shareholders' Meeting.

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