Guangdong Xinda Law Firm
Legal Opinion
SUNDIAL LAW FIRM
Guangdong Xinda Law Firm's Legal Opinion on the Achievement of Performance Assessment Indicators for the Third Unlock Period of Shenzhen Auto Electronics Co., Ltd.'s 2023 Employee Stock Ownership Plan
Xinda Stock Letter (2026) No. 010
To: Shenzhen Auto Electronics Co., Ltd.
Guangdong Xinda Law Firm ("Xinda") has been appointed by Shenzhen Auto Electronics Co., Ltd. ("the Company") as the special legal advisor for the Company's 2023 Employee Stock Ownership Plan ("the Current Employee Stock Ownership Plan"). In accordance with the "Company Law of the People's Republic of China" ("Company Law"), the "Securities Law of the People's Republic of China" ("Securities Law"), the "Guiding Opinions on Pilot Implementation of Employee Stock Ownership Plans for Listed Companies" ("Guiding Opinions"), and other relevant laws, regulations, and normative documents, the "Articles of Association of Shenzhen Auto Electronics Co., Ltd." ("Articles of Association"), and the "Shenzhen Auto Electronics Co., Ltd. 2023 Employee Stock Ownership Plan" ("Employee Stock Ownership Plan"), Xinda hereby issues this Legal Opinion regarding the achievement of performance assessment indicators for the third unlock period of the Current Employee Stock Ownership Plan.
Xinda and Xinda's lawyers make the following declarations for the purpose of issuing this Legal Opinion:
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Xinda and Xinda's lawyers, in accordance with the "Securities Law," the "Administrative Measures for Securities Legal Business of Law Firms," and the "Practice Rules for Securities Legal Business of Law Firms," and based on facts that have occurred or existed prior to the issuance date of this Legal Opinion, have strictly performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough investigations and verifications, and ensured that the facts identified in this Legal Opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without any false records, misleading statements, or material omissions, and shall bear corresponding legal responsibilities.
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Xinda has obtained the following assurances from the Company: The Company has provided Xinda's lawyers with all factual materials that Xinda's lawyers deem necessary for issuing this Legal Opinion, and the written materials and written statements provided are true and accurate.
The materials are complete, accurate, and valid, and the copies are consistent with the originals, and the signatures and/or seals on the materials are genuine and effective.
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For facts that are crucial to the issuance of this Legal Opinion but cannot be independently verified, Xinda's lawyers rely on relevant documents or opinions issued by relevant government departments, the Company, or other relevant organizations.
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Xinda's lawyers shall only express legal opinions on legal issues related to the Current Employee Stock Ownership Plan and shall not express opinions on accounting, auditing, or other professional matters. When accounting or auditing matters are involved in this Legal Opinion, they are strictly quoted from the reports issued by relevant intermediary agencies, and this does not imply any express or implied guarantee by Xinda regarding the truthfulness and accuracy of these matters.