Grandway Law Offices
Legal Opinion on the Implementation of the 2026 Stock Option Incentive Plan by Kingnet Network Co., Ltd.
Grandway Legal Opinion [2026] No. AN169-1
7th & 8th Floor, News Plaza, No. 26 Jianguomennei Avenue, Dongcheng District, Beijing, 100005
Tel: 010-88004488/66090088 Fax: 010-66090016
Definitions
In this legal opinion, unless the context otherwise requires, the following terms or abbreviations have the following meanings:
| Term | Definition |
|---|---|
| Kingnet Network, Company, Listed Company | Kingnet Network Co., Ltd. |
| Incentive Plan (Draft) | Kingnet Network Co., Ltd. 2026 Stock Option Incentive Plan (Draft) |
| Implementation Assessment Measures | Kingnet Network Co., Ltd. 2026 Stock Option Incentive Plan Implementation Assessment Management Measures |
| This Equity Incentive Plan | Kingnet Network Co., Ltd. 2026 Stock Option Incentive Plan |
| Incentive Participants | Directors, senior management, and core management and technical (business) personnel of the Company (including holding subsidiaries) as stipulated in the Incentive Plan (Draft) |
| Stock Options | The right granted by Kingnet Network to incentive participants to purchase a certain number of company shares at pre-determined conditions within a future period, according to the Incentive Plan (Draft) |
| Validity Period | The period from the date of grant of stock options to the date when all stock options granted to incentive participants are exercised or cancelled, according to the Incentive Plan (Draft) |
| Grant Date | The date on which Kingnet Network grants stock options to incentive participants after the Incentive Plan (Draft) is approved for implementation; the grant date must be a trading day |
| Waiting Period | The period from the date of completion of the stock option grant registration to the date on which the stock options become exercisable, according to the Incentive Plan (Draft) |
| Exercise | The act of incentive participants exercising stock options to purchase company shares in accordance with the arrangements of the incentive plan, according to the Incentive Plan (Draft) |
| Exercise Date | The date on which incentive participants can begin to exercise their options; the exercise date must be a trading day, according to the Incentive Plan (Draft) |
| Exercise Price | The price determined when Kingnet Network grants stock options to incentive participants, at which the incentive participants purchase the listed company's shares, according to the Incentive Plan (Draft) |
| Exercise Conditions | The conditions that must be met for incentive participants to exercise stock options, according to the Incentive Plan (Draft) |
| CSRC | China Securities Regulatory Commission |
| This Firm | Grandway Law Offices |
| Zhongshen Zhonghuan Accountants | Zhongshen Zhonghuan Certified Public Accountants (Special General Partnership) |
| Company Law | Company Law of the People's Republic of China |
| Securities Law | Securities Law of the People's Republic of China |
| Administrative Measures | Administrative Measures on Equity Incentives of Listed Companies |
| Listing Rules | Stock Listing Rules of the Shenzhen Stock Exchange |
| Self-Regulatory Guidelines | Shenzhen Stock Exchange Listed Company Self-Regulatory Guidelines No. 1 — Business Handling (2026 Revision) |
| Articles of Association | Articles of Association of Kingnet Network Co., Ltd. |
| Yuan/Ten Thousand Yuan | RMB Yuan/Ten Thousand Yuan |
Note: In this legal opinion, if the sum of the sub-items does not match the total due to rounding, it is caused by rounding.