Zhong Lun Law Firm
Supplementary Legal Opinion
To: Shanxi Huohua Group Co., Ltd.
Zhong Lun Law Firm ("the Firm") has been retained by Shanxi Huohua Group Co., Ltd. ("the Issuer," "the Company," or "Huohua Shares") as its special legal counsel for the issuance of A shares to specific objects ("the Offering"). The Firm has previously issued to the Issuer the "Zhong Lun Law Firm's Legal Opinion on Shanxi Huohua Group Co., Ltd.'s Issuance of A Shares to Specific Objects" (hereinafter referred to as the "Legal Opinion") and the "Zhong Lun Law Firm's Lawyer's Work Report on Shanxi Huohua Group Co., Ltd.'s Issuance of A Shares to Specific Objects" (hereinafter referred to as the "Lawyer's Work Report").
The Listing Review Center of the Shenzhen Stock Exchange issued the "Review Inquiry Letter [2026] No. 120006" on January 23, 2026, regarding the application of Shanxi Huohua Group Co., Ltd. for the issuance of shares to specific objects (hereinafter referred to as the "Inquiry Letter"). The Firm has further investigated the relevant matters in the Inquiry Letter and supplemented the investigation and verification of other significant legal issues related to the Issuer during the reporting period ending December 31, 2025 (hereinafter referred to as the "Supplementary Reporting Period"), and since the issuance of the Legal Opinion and the Lawyer's Work Report, to issue this Supplementary Legal Opinion.
Unless otherwise specified, terms, names, and abbreviations used in this Supplementary Legal Opinion have the same meanings as in the Firm's Legal Opinion and Lawyer's Work Report.
To issue this Supplementary Legal Opinion, the Firm's lawyers have, in accordance with the provisions of relevant laws, administrative regulations, and normative documents, and the requirements of the Firm's business rules, conducted investigations and verifications of the relevant issues involved in this Supplementary Legal Opinion based on the principles of prudence and materiality.
This Supplementary Legal Opinion is for the Issuer's Offering only and shall not be used for any other purpose. The Firm's lawyers agree that the Issuer may use this Supplementary Legal Opinion as part of its application materials for the Offering, and the Firm's lawyers shall be responsible for this Supplementary Legal Opinion.
The Firm's lawyers agree that the Issuer may quote all or part of the content of this Supplementary Legal Opinion in accordance with the review requirements of the China Securities Regulatory Commission, provided that such quotation does not lead to any ambiguity or misinterpretation of the law. Any content quoted shall be reviewed and confirmed again by the Firm's lawyers.
In accordance with the provisions of the "Securities Law," "Company Law," "Registration Management Measures," and other relevant regulations, and in accordance with the generally accepted business standards, ethical norms, and the spirit of diligence and responsibility of the Chinese legal profession, the Firm's lawyers have investigated and verified the documents and relevant facts provided by the Issuer, and hereby issue the following legal opinion:
I. Response to Inquiry Letter Question 1: (7) Based on the company's internal control system, safety production system, inventory and finished goods management system, etc., explain the soundness of the company's safety production-related internal control system construction and whether it is effectively implemented.
Response:
Investigation Process:
(1) Reviewed a series of internal control systems of the Issuer, including the "Production Management System," "Safety Production Standardization Performance Evaluation and Continuous Improvement Management System," "Hazardous Position Operator Management System," "Fire Management System," "Safety Sign Management System," "Hazard Identification, Risk Assessment and Classification Control Management System," "Production Safety Accident Hidden Danger Investigation and Management System," "Special Hazardous Operation Permit Management System," "Safety Production Education and Training Management System," "Major Hazard Source Management System," "Production Abnormal State Inspection and Handling System," "Safety and Security Management System," and "Explosives Storage, Loading, Unloading, and Transportation Management System."