Legal Opinion on the Draft 2026 Restricted Stock Incentive Plan of Beijing Shengtong Printing Co., Ltd.
1. Definitions
In this legal opinion, unless otherwise specified, the following terms or abbreviations have the following meanings:
- Shengtong Co., Ltd./Company: Refers to Beijing Shengtong Printing Co., Ltd.
- This incentive plan/this plan: Refers to the 2026 Restricted Stock Incentive Plan of Beijing Shengtong Printing Co., Ltd.
- Draft incentive plan: Refers to the "Draft 2026 Restricted Stock Incentive Plan of Beijing Shengtong Printing Co., Ltd."
- Restricted stock: Refers to the shares granted to incentive objects under the conditions and prices stipulated in this incentive plan, which are subject to a lock-up period and can only be released after meeting the conditions specified in this plan.
- Incentive objects: Refers to middle management and key personnel of the company (including wholly-owned subsidiaries, holding subsidiaries, and holding grand-subsidiaries) who are granted restricted stocks according to this plan.
- Grant date: The date on which the company grants restricted stocks to the incentive objects, which must be a trading day.
- Grant price: The price determined by the company at which the incentive objects can acquire the company's shares upon the grant of restricted stocks.
- Valid period: The period from the completion of the initial registration of restricted stocks to the date when all granted restricted stocks are released from restrictions or repurchased and canceled.
- Lock-up period: The period during which the incentive objects are prohibited from transferring, using as collateral, or repaying debts with the granted restricted stocks.
- Release period: The period during which the restricted stocks held by the incentive objects can be released and listed for trading after meeting the conditions specified in this incentive plan.
- Release conditions: The conditions that must be met for the incentive objects to release the restricted stocks granted under this plan.
- Company Law: Refers to the "Company Law of the People's Republic of China (2023 Revision)."
- Securities Law: Refers to the "Securities Law of the People's Republic of China (2019 Revision)."
- Management Measures: Refers to the "Management Measures for Equity Incentives of Listed Companies (2025 Revision)."
- Self-Regulatory Guidelines: Refers to the "Self-Regulatory Guidelines No. 1 for Listed Companies of Shenzhen Stock Exchange - Business Handling (2025 Revision)."
- Articles of Association: Refers to the Articles of Association of Beijing Shengtong Printing Co., Ltd.
- Assessment Management Measures: Refers to the "Assessment Management Measures for the Implementation of the 2026 Restricted Stock Incentive Plan of Beijing Shengtong Printing Co., Ltd."
- CSRC: Refers to the China Securities Regulatory Commission.
- SZSE: Refers to the Shenzhen Stock Exchange.
- This firm: Refers to Grandway Law Offices.
- This legal opinion: Refers to the "Legal Opinion on the Draft 2026 Restricted Stock Incentive Plan of Beijing Shengtong Printing Co., Ltd."
- Yuan/ten thousand/one hundred million: Refers to Renminbi yuan/ten thousand/one hundred million.
If there are discrepancies between partial totals and the sum of individual items in this legal opinion, they are due to rounding.
2. Legal Opinion
Grandway Law Offices issues this legal opinion based on the agreement signed with Shengtong Co., Ltd. and the entrustment of Shengtong Co., Ltd. to act as special legal counsel for the implementation of this incentive plan. According to the provisions of the Company Law, Securities Law, Management Measures, Self-Regulatory Guidelines, and other relevant laws, regulations, rules, normative documents, and the Articles of Association, the lawyers of this firm provide legal opinions on the relevant matters involved in this incentive plan.