JINGTIAN & GONGCHENG Beijing Jingtian & Gongcheng Law Firm
Regarding Guangdong Xianglu Tungsten Industry Co., Ltd.'s 2023 Private Placement of A Shares Supplementary Legal Opinion (I)
To: Guangdong Xianglu Tungsten Industry Co., Ltd.
Beijing Jingtian & Gongcheng Law Firm (hereinafter referred to as "the Firm") has been retained by the issuer as the special legal counsel for Guangdong Xianglu Tungsten Industry Co., Ltd. (hereinafter referred to as "the Issuer" or "the Company" or "Xianglu Tungsten") in its 2023 private placement of A shares (hereinafter referred to as "the Offering"). In accordance with relevant laws, regulations, and the "Compilation Rules for Information Disclosure of Publicly Issued Securities No. 12 – Legal Opinions and Lawyer's Reports on Publicly Issued Securities" issued by the China Securities Regulatory Commission (CSRC), the "Administrative Measures for the Registration of Public Offerings of Securities," and the "Administrative Measures for Lawyers Engaging in Securities Legal Business" and "Practice Rules for Lawyers Engaging in Securities Legal Business (Trial)" jointly issued by the CSRC and the Ministry of Justice, and in accordance with the generally accepted business standards, ethical norms, and the spirit of diligence and conscientiousness of the legal profession, the Firm has issued the "Beijing Jingtian & Gongcheng Law Firm's Legal Opinion on Guangdong Xianglu Tungsten Industry Co., Ltd.'s 2023 Private Placement of A Shares" (hereinafter referred to as "Legal Opinion") and the "Beijing Jingtian & Gongcheng Law Firm's Lawyer's Report on Guangdong Xianglu Tungsten Industry Co., Ltd.'s 2023 Private Placement of A Shares" (hereinafter referred to as "Lawyer's Report").
Based on the "Inquiry Letter on the Review of Guangdong Xianglu Tungsten Industry Co., Ltd.'s Application for Private Placement of Shares" (Inquiry Letter [2025] No. 120052) (hereinafter referred to as "Inquiry Letter") issued by the Listing Review Center of the Shenzhen Stock Exchange on November 12, 2025, the Firm's lawyers, after further investigation into the relevant matters of the Issuer, hereby issue this Supplementary Legal Opinion (I) (hereinafter referred to as "this Supplementary Legal Opinion"). Regarding the PRC legal matters involved in the "Inquiry Letter," the Firm's lawyers, as legal professionals, have exercised special due diligence; regarding the financial and accounting and other non-legal matters involved in the "Inquiry Letter," the Firm's lawyers, as non-financial professionals, have exercised general due diligence.
The statements made by the Firm and its lawyers in the Legal Opinion and Lawyer's Report also apply to this Supplementary Legal Opinion. Specifically, the Firm only expresses opinions on the legal issues related to the Issuer's Offering and only based on current PRC laws. The Firm does not express opinions on professional matters and reports outside of legal matters, such as accounting, auditing, asset valuation, financial analysis, investment decisions, or business development. Any citation of certain data, audit reports, or business reports and their conclusions in this Supplementary Legal Opinion does not imply any express or implied guarantee by the Firm of the truthfulness, accuracy, or completeness of such data, conclusions, or reports. The Firm and its lawyers do not have the appropriate qualifications to review and make evaluations of such data, reports, and their conclusions, nor do they have the appropriate qualifications to express opinions on matters within the jurisdiction of other countries or regions.
Unless otherwise stated, the meanings of abbreviations used in this Supplementary Legal Opinion are the same as those used in the Legal Opinion and Lawyer's Report.
This Supplementary Legal Opinion only expresses legal opinions on the parts that need to be supplemented in the Legal Opinion and Lawyer's Report. It is a supplement and an inseparable part of the Legal Opinion and Lawyer's Report. If there is any inconsistency between the content of this Supplementary Legal Opinion and the aforementioned legal documents, this Supplementary Legal Opinion shall prevail.