Legal Opinion
Beijing Zhonglun Law Firm on Suzhou Hengmingda Electronics Technology Co., Ltd.'s 2026 Third Extraordinary General Meeting of Shareholders
To: Suzhou Hengmingda Electronics Technology Co., Ltd.
Beijing Zhonglun Law Firm (hereinafter referred to as "this Firm") has been entrusted by Suzhou Hengmingda Electronics Technology Co., Ltd. (hereinafter referred to as "the Company") to appoint lawyers from this Firm to witness the legality of the Company's 2026 Third Extraordinary General Meeting of Shareholders (hereinafter referred to as "this Meeting") and to issue this legal opinion.
This Firm and its lawyers have strictly fulfilled their statutory duties in accordance with the provisions of the "Securities Law of the People's Republic of China" (hereinafter referred to as "the Securities Law"), the "Administrative Measures for Law Firms Engaging in Securities Legal Business," and the "Practice Rules for Law Firms Engaging in Securities Legal Business (Trial)" as well as facts that have occurred or existed prior to the issuance date of this legal opinion. They have adhered to the principles of diligence and good faith, conducted thorough verification, and ensured that the facts recognized in this legal opinion are true, accurate, and complete, and that the conclusive opinions expressed are legal and accurate, without any false records, misleading statements, or significant omissions, and bear corresponding legal responsibilities.
This legal opinion is issued based on the "Company Law of the People's Republic of China" (hereinafter referred to as "the Company Law"), the "Securities Law," the "Rules for General Meetings of Shareholders of Listed Companies" issued by the China Securities Regulatory Commission (hereinafter referred to as "CSRC"), and the "Implementation Rules for Online Voting at General Meetings of Shareholders of Listed Companies on the Shenzhen Stock Exchange" (hereinafter referred to as "the Online Voting Implementation Rules"), as well as the current effective laws, regulations, normative documents, and the "Articles of Association of Suzhou Hengmingda Electronics Technology Co., Ltd." (hereinafter referred to as "the Articles of Association") and the "Rules of Procedure for Shareholders' Meetings of Suzhou Hengmingda Electronics Technology Co., Ltd." (hereinafter referred to as "the Rules of Procedure").
To issue this legal opinion, the lawyers from this Firm reviewed the relevant documents and materials for this Meeting. The lawyers received the following assurances from the Company, namely that it has provided all materials deemed necessary for the issuance of this legal opinion, and that the original materials, copies, and oral testimonies provided meet the requirements of being true, accurate, and complete, and that the relevant copies and materials are consistent with the original documents.
In this legal opinion, the lawyers from this Firm only express opinions on the convening and holding procedures of this Meeting, the qualifications of attendees (excluding the qualifications of shareholders voting online), the qualifications of the convener, and the voting procedures and results, without commenting on the content of the proposals discussed at the meeting or the truthfulness and accuracy of the facts or data expressed in those proposals. This legal opinion is solely for the purpose of witnessing the legality of matters related to this Meeting and shall not be used for any other purpose.
The lawyers from this Firm have verified the relevant documents and facts provided by the Company in accordance with legal requirements, recognized business standards, ethical norms, and the spirit of diligence and good faith, and now issue the following legal opinions: