Beijing DeHeng Law Offices
Regarding
Beijing North Mo-High-Tech Friction Material Co., Ltd.
2025 Annual Issuance of Securities to Specific Targets
Supplementary Legal Opinion (I)
DeHeng No. 01F20260245-4
To: Beijing North Mo-High-Tech Friction Material Co., Ltd.
Pursuant to the Special Legal Service Agreement signed between the Issuer and our firm, we have been engaged as the special legal counsel for the Issuer's current issuance. DeHeng, formerly known as the China Law Firm Center, was established in Beijing in January 1993 with the approval of the Ministry of Justice of the People's Republic of China. It was renamed DeHeng Law Offices in 1995, Beijing DeHeng Law Offices in 2001, and Beijing DeHeng Law Offices in 2011. DeHeng currently holds a Law Firm Practice License issued by the Beijing Municipal Bureau of Justice (License No. 31110000400000448M). Its registered address is 12th Floor, Tower B, Fukai Building, 19 Financial Street, Xicheng District, Beijing, and its person-in-charge is Wang Li. In 2025, the total number of lawyers at our firm engaged in securities legal business is 617.
In accordance with the Securities Law, the Company Law, the China Securities Regulatory Commission's "Compilation Rules for Information Disclosure by Companies Offering Securities to the Public No. 12 — Legal Opinion and Lawyer's Work Report for Public Offering of Securities," the "Administrative Measures for Law Firms Engaging in Securities Legal Business," and the "Practice Rules for Law Firms Engaging in Securities Legal Business (Trial)," our lawyers have previously issued the "Beijing DeHeng Law Offices' Legal Opinion on the 2025 Annual Issuance of Securities to Specific Targets by Beijing North Mo-High-Tech Friction Material Co., Ltd." (hereinafter referred to as the "Legal Opinion") and the "Beijing DeHeng Law Offices' Lawyer's Work Report on the 2025 Annual Issuance of Securities to Specific Targets by Beijing North Mo-High-Tech Friction Material Co., Ltd." (hereinafter referred to as the "Lawyer's Work Report").
Given that the Shenzhen Stock Exchange issued the "Inquiry Letter on the Application of Beijing North Mo-High-Tech Friction Material Co., Ltd. for Issuance of Securities to Specific Targets" (Audit Letter [2026] No. 120020) (hereinafter referred to as the "Inquiry Letter") on April 15, 2026, our lawyers have strictly performed their statutory duties in accordance with relevant laws, administrative regulations, rules, and normative documents, as well as facts that have occurred or existed prior to the date of this supplementary legal opinion. We have followed the principles of diligence and good faith, conducted sufficient supplementary verification of the issues raised in the Inquiry Letter, and ensured that the facts recognized in this supplementary legal opinion are true, accurate, and complete. The concluding opinions expressed herein are legal and accurate, free from false records, misleading statements, or major omissions, and we assume corresponding legal liability.
This supplementary legal opinion is an amendment and supplement to the "Legal Opinion" and "Lawyer's Work Report," and constitutes an integral part thereof. Except for the matters supplemented and updated herein, the contents of the "Legal Opinion" and "Lawyer's Work Report" remain valid. In the event of any inconsistency between the "Legal Opinion," "Lawyer's Work Report," and this supplementary legal opinion, this supplementary legal opinion shall prevail.
Unless otherwise specified, the statements, definitions, and other relevant contents in the "Legal Opinion" and "Lawyer's Work Report" apply to this supplementary legal opinion.
Based on the above, our lawyers, in accordance with the Company Law, the Securities Law, the Registration Measures, and other relevant laws, regulations, and the rules of the CSRC and the Shenzhen Stock Exchange, and following recognized professional standards, ethical norms, and the spirit of diligence, hereby issue this supplementary legal opinion as follows:
Question 1