Beijing Tian Yuan Law Firm
TIAN YUAN LAW FIRM
Legal Opinion on the 2026 Second Extraordinary General Meeting of Chengzhan Optoelectronics (Xiamen) Co., Ltd.
Jing Tian Gu Zi (2026) No. 533
To: Chengzhan Optoelectronics (Xiamen) Co., Ltd.
Chengzhan Optoelectronics (Xiamen) Co., Ltd. (hereinafter referred to as the "Company") convened its 2026 Second Extraordinary General Meeting (hereinafter referred to as the "Shareholders' Meeting") using a combination of on-site voting and online voting. The on-site meeting was held at 16:00 on August 10, 2026, in the company's conference room at No. 60, Xinglin South Road, Jimei District, Xiamen City, Fujian Province. Beijing Tian Yuan Law Firm (hereinafter referred to as the "Firm") was appointed by the Company to send its lawyers to attend this Shareholders' Meeting. In accordance with the "Company Law of the People's Republic of China," the "Securities Law of the People's Republic of China" (hereinafter referred to as the "Securities Law"), the "Rules for Shareholders' Meetings of Listed Companies" (hereinafter referred to as the "Shareholders' Meeting Rules"), and the "Articles of Association of Chengzhan Optoelectronics (Xiamen) Co., Ltd." (hereinafter referred to as the "Articles of Association"), and other relevant regulations, this legal opinion is issued on matters concerning the convening and holding of this Shareholders' Meeting, the qualifications of attendees, the qualifications of the convener, the voting procedures, and the voting results.
To issue this legal opinion, the Firm's lawyers have reviewed the "Announcement of the Resolution of the 18th Meeting of the Third Board of Directors of Chengzhan Optoelectronics (Xiamen) Co., Ltd." and the "Notice of Chengzhan Optoelectronics (Xiamen) Co., Ltd. on Convening the 2026 Second Extraordinary General Meeting" (hereinafter referred to as the "Notice of Convening the Shareholders' Meeting"), as well as other documents and materials deemed necessary by the Firm's lawyers. They have also reviewed the identities and qualifications of the shareholders attending the on-site meeting, witnessed the convening of the Shareholders' Meeting, and participated in the on-site supervision and vote counting for the proposals of this Shareholders' Meeting.
The Firm and the handling 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 exist prior to the issuance date of this legal opinion, strictly performed their statutory duties, adhered to the principles of diligence, due care, and good faith, conducted thorough investigations and verifications, and ensured that the facts identified in this legal opinion are true, accurate, and complete. The conclusions made are legal and accurate, and do not contain any false records, misleading statements, or material omissions, and the Firm assumes corresponding legal responsibilities.
The Firm and the handling lawyers agree that this legal opinion will be submitted to the Shenzhen Stock Exchange (hereinafter referred to as the "SZSE") as a legal document for the announcement of this Shareholders' Meeting, for review and announcement along with other announcement documents, and will be legally responsible for the issuance of this legal opinion.
The Firm's lawyers, in accordance with the generally accepted professional standards, ethical norms, and the spirit of diligence and due care of the legal profession, have investigated and verified the documents and relevant facts provided by the Company, and hereby issue the legal opinion as follows: