AllBright Law Offices
Legal Opinion on the 2026 Restricted Stock Incentive Plan of Zhengzhou Sanhui Electric Co., Ltd.
To: Zhengzhou Sanhui Electric Co., Ltd.
AllBright Law Offices (hereinafter referred to as "AllBright" or "our firm") was engaged by Zhengzhou Sanhui Electric Co., Ltd. (hereinafter referred to as "Sanhui Electric" or the "Company") to serve as the special legal counsel for the 2026 Restricted Stock Incentive Plan (hereinafter referred to as the "Incentive Plan"). This legal opinion is issued in accordance with the Company Law of the People's Republic of China (2023 Revision), the Securities Law of the People's Republic of China (2025 Amendment), the Administrative Measures for Equity Incentives of Listed Companies (2025 Amendment), the Shenzhen Stock Exchange Self-Regulatory Guidelines for Listed Companies No. 1—Business Handling (2026 Revision), and the Rules Governing the Listing of Stocks on the Shenzhen Stock Exchange.
The Company has provided all necessary original documents, copies, and confirmations required for this opinion, guaranteeing their authenticity, accuracy, and completeness.
I. Conditions for the Company to Implement the Incentive Plan
1. Basic Information of the Company
Upon verification, the Company holds a Business License issued by the Zhengzhou Market Supervision and Administration Bureau. The basic information is as follows:
| Item | Details |
|---|---|
| Enterprise Name | Zhengzhou Sanhui Electric Co., Ltd. |
| Unified Social Credit Code | 914101002680819647 |
| Address | 102 Chuangguang Road, Zhengzhou Area (Economic Development Zone), Henan Pilot Free Trade Zone |
| Legal Representative | Hu Kun |
| Registered Capital | 130.634 million RMB |
| Paid-in Capital | 130.634 million RMB |
| Company Type | Joint Stock Limited Company (Listed) |
| Business Scope | General items: Electronic component manufacturing; power electronic component manufacturing; special electronic equipment manufacturing; special electronic material manufacturing; special instrument manufacturing; other electronic device manufacturing; computer hardware/software and peripheral equipment manufacturing; industrial control computer and system manufacturing; electronic product sales; power electronic component sales; electronic component wholesale; technical services, development, consulting, exchange, transfer, and promotion; loading, unloading, and handling; general cargo warehousing services (excluding hazardous chemicals and other items requiring licensing); terminal metering equipment manufacturing and sales; information system integration services; IoT technology R&D and services; information consulting services (excluding licensed consulting); charging pile sales; power transmission and distribution control equipment manufacturing and sales; smart power transmission and distribution control equipment sales; general mechanical equipment installation services; charging control equipment leasing; non-residential real estate leasing; housing leasing; human resources services (excluding job intermediary and labor dispatch); power distribution switch control equipment R&D, manufacturing, and sales; battery manufacturing and sales; battery parts production and sales; energy storage technology services; technology import/export; import/export of goods (except for items subject to approval according to law, business activities are carried out independently with the business license) |
| Date of Establishment | July 16, 1996 |
| Business Term | July 16, 1996 to long-term |
| Registration Authority | Zhengzhou Market Supervision and Administration Bureau |
- Sanhui Electric is a joint-stock limited company established and existing in accordance with the law
According to the "Reply on Approving the Initial Public Offering of Shares of Zhengzhou Sanhui Electric Co., Ltd." (Zheng Jian Xu Ke [2017] No. 314) issued by the China Securities Regulatory Commission (hereinafter referred to as the "CSRC"), the RMB ordinary shares issued by the Company are listed on the Shenzhen Stock Exchange. The Company's stock abbreviation is "Sanhui Electric" and the stock code is "002857". The 20 million shares publicly issued this time were listed for trading starting from March 23, 2017.