To: Wuhan Zhongyuan Huadian Technology Co., Ltd.
Qiyuan Law Firm (hereinafter referred to as "the Firm") has been retained by Wuhan Zhongyuan Huadian Technology Co., Ltd. (hereinafter referred to as "Zhongyuan Shares," "the Issuer," or "the Company") as its special legal counsel for the Issuer's application for a private placement of shares in 2025 (hereinafter referred to as "the Offering").
The Firm has previously issued the "Lawyer's Work Report of Qiyuan Law Firm on the 2025 Private Placement of Shares by Wuhan Zhongyuan Huadian Technology Co., Ltd." (hereinafter referred to as the "Lawyer's Work Report"), the "Legal Opinion of Qiyuan Law Firm on the 2025 Private Placement of Shares by Wuhan Zhongyuan Huadian Technology Co., Ltd." (hereinafter referred to as the "Legal Opinion"), the "Supplementary Legal Opinion (I) of Qiyuan Law Firm on the 2025 Private Placement of Shares by Wuhan Zhongyuan Huadian Technology Co., Ltd." (hereinafter referred to as "Supplementary Legal Opinion (I)"), the "Revised Draft of Supplementary Legal Opinion (I) of Qiyuan Law Firm on the 2025 Private Placement of Shares by Wuhan Zhongyuan Huadian Technology Co., Ltd." (hereinafter referred to as "Revised Draft of Supplementary Legal Opinion (I)"), and the "Supplementary Legal Opinion (II) of Qiyuan Law Firm on the 2025 Private Placement of Shares by Wuhan Zhongyuan Huadian Technology Co., Ltd." (hereinafter referred to as "Supplementary Legal Opinion (II)"; together with the Legal Opinion, Supplementary Legal Opinion (I), and Revised Draft of Supplementary Legal Opinion (I), collectively referred to as the "Original Legal Opinions").
Given that the Issuer has made corresponding adjustments to the Offering plan, the Firm has conducted supplementary verification on the matters related to these adjustments and hereby issues the "Supplementary Legal Opinion (III) of Qiyuan Law Firm on the 2025 Private Placement of Shares by Wuhan Zhongyuan Huadian Technology Co., Ltd." (hereinafter referred to as "this Supplementary Legal Opinion").
This Supplementary Legal Opinion is a supplementary document to the Lawyer's Work Report and the Original Legal Opinions. It should be used in conjunction with the Lawyer's Work Report and the Original Legal Opinions. In case of any inconsistency between this Supplementary Legal Opinion and the Lawyer's Work Report or the Original Legal Opinions, this Supplementary Legal Opinion shall prevail.
The terms and abbreviations used in this Supplementary Legal Opinion, unless otherwise defined or indicated, have the same meanings as those used in the Lawyer's Work Report and the Original Legal Opinions. The statements made in the Lawyer's Work Report and the Original Legal Opinions also apply to this Supplementary Legal Opinion.
The Firm agrees that the Issuer may use this Supplementary Legal Opinion as a mandatory legal document for its application to the China Securities Regulatory Commission (CSRC) and the Shenzhen Stock Exchange (SZSE), and will submit it along with other application materials, assuming corresponding legal responsibilities. This Supplementary Legal Opinion is for the sole purpose of the Offering and may not be used for any other purpose without the Firm's prior written consent.
Part One: Adjustment of the Offering Plan
I. Details of the Offering Plan Adjustment
Based on the documents provided by the Issuer and verified by the Firm's lawyers, the Issuer convened the 19th (Extraordinary) Meeting of the Sixth Board of Directors on June 12, 2026. The meeting deliberated and approved the "Proposal on Adjusting the Offering Price and Number of Shares for the Private Placement" and the "Proposal on the Company Signing a Supplementary Agreement to the Conditional Share Subscription Agreement with the Specific Investor and Related Party Transactions." The Issuer has accordingly signed a "Supplementary Agreement to the Conditional Share Subscription Agreement" with the subscribers Zhu Shuangquan and Zhu Shunquan. The details of the plan adjustment are as follows: