Legal Opinion on the Shareholders' Meeting of Shanghai Shunhao New Materials Technology Co., Ltd.
Shanghai Zhengce Law Firm (hereinafter referred to as "the Firm") has been entrusted by Shanghai Shunhao New Materials Technology Co., Ltd. (hereinafter referred to as "the Company") to appoint lawyers Wang Yongjie and Feng Suying (hereinafter referred to as "the Firm's Lawyers") to attend the Company's 2025 Annual General Meeting (hereinafter referred to as "this Shareholders' Meeting" or "this Meeting") scheduled for May 28, 2026, at 14:00 in the Company's conference room located at 200 Zhenchen Road, Putuo District, Shanghai. This legal opinion is issued 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 issued by the China Securities Regulatory Commission (hereinafter referred to as "the Rules for Shareholders' Meetings"), and the Implementation Rules for Online Voting at Shareholders' Meetings of Listed Companies on the Shenzhen Stock Exchange (2025 Revision) (hereinafter referred to as "the Online Voting Implementation Rules"), as well as the relevant provisions of the Articles of Association of Shanghai Shunhao New Materials Technology Co., Ltd. (hereinafter referred to as "the Articles of Association") and the Rules of Procedure for Shareholders' Meetings of Shanghai Shunhao New Materials Technology Co., Ltd.
To issue this legal opinion, the Firm's Lawyers reviewed the relevant documents and materials for this Shareholders' Meeting. The Company has assured the Firm's witnessing lawyers that it has provided all materials deemed necessary for the issuance of this legal opinion, and that the original materials, copies, and oral testimonies provided are true, accurate, and complete, with no concealment or misleading information. The relevant copies and materials are consistent with the original materials.
In this legal opinion, the Firm only expresses opinions on the convening and holding procedures of this Shareholders' Meeting, the qualifications of attendees, the qualifications of the convener, and the voting procedures and results, and does not express opinions on the content of the proposals reviewed at this Shareholders' Meeting or the truthfulness and accuracy of the facts or data presented in those proposals. The Firm only expresses opinions based on the currently effective laws and regulations within China and does not express opinions based on any foreign laws.
The Firm has strictly fulfilled its statutory duties in accordance with the aforementioned laws, administrative regulations, rules, and normative documents, as well as the relevant provisions of the Articles of Association, and has conducted thorough verification of the facts that occurred or existed prior to the issuance date of this legal opinion. The Firm ensures that the facts recognized in this legal opinion are true, accurate, and complete, and that the conclusive opinions expressed are legal and accurate, with no false records, misleading statements, or significant omissions, and assumes corresponding legal responsibilities.
The Firm agrees to use this legal opinion as part of the announcement materials for this Shareholders' Meeting, to be submitted along with other meeting documents to the relevant institutions for announcement. Furthermore, without the Firm's consent, this legal opinion shall not be used by any other person for any other purpose.
The Firm's lawyers attended this Shareholders' Meeting in accordance with the requirements of relevant laws and regulations, and in accordance with the recognized business standards, ethical norms, and diligence principles of the legal profession, and verified the relevant facts regarding the convening and holding of this Shareholders' Meeting, and hereby issues the following legal opinions: