Hubei Shouyi Law Firm
Regarding Jifeng Sanong Technology Service Co., Ltd.
2025 Non-Public Offering of Shares
Supplementary Legal Opinion (I)
(Revised Draft)
China, Wuhan
20th Floor, Building 3, Wanda Global International Center, No. 28 Songzhu Road, Wuchang District, Wuhan, Hubei Province
Tel: 027-88077353 Postal Code: 430062
Website: http://www.hubeishouyi.com
To: Shenzhen Stock Exchange
Hubei Shouyi Law Firm has been engaged by Jifeng Sanong Technology Service Co., Ltd. as special legal counsel to provide legal services for the company's 2025 non-public offering of shares, with attorneys Gong Cheng and Xia Jin assigned to the project.
In accordance with the Company Law, Securities Law, Lawyers Law, Administrative Measures for Registration, Compilation Rules No. 12, Administrative Measures for Securities Legal Business, and Practice Rules for Securities Legal Business, our firm has previously issued the "Legal Opinion of Hubei Shouyi Law Firm on the 2025 Non-Public Offering of Shares by Jifeng Sanong Technology Service Co., Ltd." (hereinafter referred to as the "Legal Opinion") and the "Attorney's Work Report of Hubei Shouyi Law Firm on the 2025 Non-Public Offering of Shares by Jifeng Sanong Technology Service Co., Ltd." (hereinafter referred to as the "Attorney's Work Report").
In response to the "Inquiry Letter on the Application for Non-Public Offering of Shares by Jifeng Sanong Technology Service Co., Ltd." (Audit Letter [2026] No. 020031) issued by the Listing Review Center of the Shenzhen Stock Exchange on April 20, 2026 (hereinafter referred to as the "Inquiry Letter"), our attorneys have conducted supplementary verification and issued this supplementary legal opinion.
The "Reporting Period" and "Recent Three Years" referred to in this supplementary legal opinion refer to the period from January 1, 2023, to December 31, 2025, and the years 2023, 2024, and 2025. The "Supplementary Reporting Period" refers to the period from October 1, 2025, to December 31, 2025.
This supplementary legal opinion constitutes a supplement to the "Legal Opinion" and "Attorney's Work Report" and is intended solely for the issuer's use in this offering. Our firm consents to this document being filed as a required legal document for the issuer's application.
The statements made in the "Legal Opinion" and "Attorney's Work Report" also apply to this supplementary legal opinion. Unless otherwise specified, terms used herein have the same meanings as those in the "Legal Opinion" and "Attorney's Work Report."
Our attorneys have issued this supplementary legal opinion based on professional standards, ethical norms, and due diligence.
I. Inquiry Question One
According to the application documents, the company's main business revenue is derived from agricultural machinery distribution, agricultural machinery manufacturing, and cargo vehicle sales. The sales model consists of direct chain sales and distributor agency sales. During the reporting period, the company's operating income was 2,707.7164 million yuan, 2,649.6508 million yuan, 2,708.9537 million yuan, and 2,224.3033 million yuan, respectively. Net profit after deducting non-recurring gains and losses was 8.1164 million yuan, 12.9537 million yuan, -20.7887 million yuan, and -9.6935 million yuan, respectively, showing significant volatility and continuous losses over the last year and one period. The gross profit margin was 14.87%, 15.37%, 13.26%, and 10.76%, showing a downward trend. According to the recently disclosed "2025 Annual Report," the company achieved an operating income of 2,765.7666 million yuan in 2025, a year-on-year increase of 2.10%, and a net profit after deducting non-recurring gains and losses of -34.3221 million yuan, a year-on-year decline of 65.10%.
The concentration of the top five suppliers is approximately 60%. The company's competitive advantages include brand distribution authorization; as of the end of the reporting period, the issuer has obtained distribution authorization for nearly 200 agricultural machinery brands.