Grandall Law Firm (Shanghai)
Legal Opinion on the 2026 Restricted Stock Incentive Plan (Draft Revision) of Yunnan Energy New Material Co., Ltd.
To: Yunnan Energy New Material Co., Ltd.
Grandall Law Firm (Shanghai) was engaged by Energy New Material to issue this legal opinion regarding the 2026 Restricted Stock Incentive Plan (Draft Revision) in accordance with the Company Law, Securities Law, Administrative Measures, Guidelines for Self-Regulation No. 1, and other relevant laws, regulations, and the Articles of Association.
Section 1 Introduction
Our lawyers have issued this legal opinion based on facts existing prior to the date of issuance and in accordance with current laws, regulations, and CSRC requirements, with the following declarations:
(1) The firm and its lawyers have strictly fulfilled their statutory duties, followed the principles of diligence and good faith, and conducted sufficient verification to ensure the facts are true, accurate, and complete, and the conclusions are legal and accurate.
(2) The firm consents to the use of this legal opinion as a mandatory legal document for the incentive plan and agrees to its public disclosure.
(3) The company guarantees that it has provided all necessary, true, complete, and valid original written materials, copies, or oral testimony required for the issuance of this legal opinion.
Table of Contents
| Section | Page |
|---|---|
| Definitions | 2 |
| Section 1 Introduction | 4 |
| Section 2 Main Body | 6 |
| 1. Eligibility of the Subject for the Incentive Plan | 6 |
| 2. Main Content and Compliance of the Incentive Plan | 8 |
| 3. Statutory Procedures Required for the Incentive Plan | 16 |
| 4. Information Disclosure of the Incentive Plan | 17 |
| 5. No Financial Assistance Provided by the Company | 18 |
| 6. Impact on the Company and Shareholders' Interests | 18 |
| 7. Recusal of Interested Directors | 19 |
| 8. Conclusion | 19 |
| Section 3 Signature Page | 20 |
Definitions
Unless otherwise specified, the following terms have the specific meanings defined below: