King & Wood Mallesons Guangdong Province, Shenzhen City, Nanshan District, Keyuan South Road No. 2666, China Resources Tower, 28th Floor, Postal Code: 518052 28F, China Resources Tower 2666 Keyuan South Road, Nanshan District Shenzhen, Guangdong, 518052, PRC T +86 755 2216 3333 F +86 755 2216 3380 www.kingandwood.com Shenzhen King & Wood Law Firm Regarding Shenzhen Rui Ming Technology Co., Ltd.'s 2025 Stock Option Incentive Plan: Legal Opinion on the Cancellation of Stock Options and Achievement of First Vesting Conditions To: Shenzhen Rui Ming Technology Co., Ltd. Shenzhen King & Wood Law Firm (hereinafter referred to as "this firm") has been retained by Shenzhen Rui Ming Technology Co., Ltd. (hereinafter referred to as "the Company") to provide this legal opinion based on the "Company Law of the People's Republic of China" (hereinafter referred to as "Company Law"), the "Securities Law of the People's Republic of China" (hereinafter referred to as "Securities Law"), the "Administrative Measures for Stock Incentives of Listed Companies" (hereinafter referred to as "Administrative Measures") issued by the China Securities Regulatory Commission (hereinafter referred to as "CSRC"), the "Shenzhen Stock Exchange Stock Listing Rules," and the "Shenzhen Stock Exchange Listed Company Self-Regulation Guidelines No. 1 — Business Handling" (hereinafter collectively referred to as "Laws and Regulations"), as well as the "Articles of Association of Shenzhen Rui Ming Technology Co., Ltd." (hereinafter referred to as "Articles of Association") and the "Shenzhen Rui Ming Technology Co., Ltd. 2025 Stock Option Incentive Plan (Draft)" (hereinafter referred to as the "2025 Incentive Plan"). This legal opinion addresses the cancellation of certain granted but unexercised stock options (hereinafter referred to as "this cancellation") and the achievement of the first vesting conditions (hereinafter referred to as "this exercise," collectively referred to as "this cancellation and exercise") under the "2025 Stock Option Incentive Plan" (hereinafter referred to as "this Incentive Plan"). This firm and its practicing lawyers have, in accordance with the "Securities Law," the "Administrative Measures for Securities Legal Business of Law Firms," and the "Practice Rules for Securities Legal Business of Law Firms (Trial)," and based on facts that have occurred or existed prior to the issuance date of this legal opinion, strictly performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough investigations and verifications, and ensured that the facts identified in this legal opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without any false records, misleading statements, or material omissions, and shall bear corresponding legal responsibilities. This firm expresses opinions solely on legal issues related to the Company's cancellation and exercise, and only based on the laws and regulations of the People's Republic of China (including the Hong Kong Special Administrative Region, the Macau Special Administrative Region, and Taiwan Province of China). This firm does not express legal opinions based on any foreign laws. This firm does not express opinions on the reasonableness of the value of the underlying shares involved in this cancellation and exercise, the performance standards, or non-legal professional matters such as accounting and finance. While this firm has exercised due diligence in citing financial data or conclusions in this legal opinion, such citations should not be construed as an express or implied guarantee of the truthfulness or accuracy of such data or conclusions. For facts that are crucial to the issuance of this legal opinion and cannot be independently verified, this firm relies on the statements or certificates issued by relevant government departments, the Company, or other relevant entities. The Company has provided the following assurances to this firm for the issuance of this legal opinion:
- The Company has provided this firm and its practicing lawyers with all original written materials, duplicate materials, photocopies, confirmation letters, or certificates requested for the issuance of this legal opinion.
- The documents and materials provided by the Company to this firm and its practicing lawyers are true, accurate, complete, and valid, without any concealment, falsification, or material omissions. For any photocopi