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Beijing Weiheng (Shanghai) Law Firm’s Legal Opinion on the 2026 Restricted Stock Incentive Plan (Draft) of Shanghai Annoque Group Co., Ltd.

Shanghai Anoky Group Co., Ltd.··17 pages

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This document is a legal opinion issued by Beijing Weiheng (Shanghai) Law Firm regarding the 2026 Restricted Stock Incentive Plan (Draft) of Shanghai Annoque Group Co., Ltd. The firm has reviewed the plan's compliance with relevant laws, regulations, and the company's articles of association. The opinion confirms the company's eligibility to implement the incentive plan and verifies the legality of the proposed procedures and terms.

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Full Translation

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Beijing Weiheng (Shanghai) Law Firm

Legal Opinion on the 2026 Restricted Stock Incentive Plan (Draft) of Shanghai Annoque Group Co., Ltd.

[Chart: Beijing Weiheng Law Firm Logo]

Address: 26F, Tower S1, Bund Finance Center, 600 Zhongshan 2nd Road (E), Huangpu, Shanghai

Tel: (021)22257666

Fax: (021)22257667

Table of Contents

Definitions

I. Eligibility of the Company to Implement the Incentive Plan

II. Main Content and Compliance of the Incentive Plan

III. Statutory Procedures Involved in the Incentive Plan

IV. Determination of Participants in the Incentive Plan

V. Information Disclosure of the Incentive Plan

VI. Whether the Company Provides Financial Assistance to Participants

VII. Impact of the Incentive Plan on the Company and All Shareholders

VIII. Recusal of Interested Directors

IX. Concluding Opinion

In this legal opinion, unless the context otherwise requires, the following terms or abbreviations have the following meanings:

TermDefinition
Company, Annoque, Listed CompanyShanghai Annoque Group Co., Ltd. (formerly known as Shanghai Annoque Textile Chemical Co., Ltd.)
Incentive Plan, This PlanShanghai Annoque Group Co., Ltd. 2026 Restricted Stock Incentive Plan
Incentive Plan (Draft)Shanghai Annoque Group Co., Ltd. 2026 Restricted Stock Incentive Plan (Draft)
Restricted Stock, Class I Restricted StockCompany shares granted to participants at conditions and prices stipulated by this plan, subject to a lock-up period and releasable upon meeting specified conditions
ParticipantDirectors, senior management, middle management, and core technical (business) personnel of the company (including subsidiaries and branches) receiving restricted stock
Grant DateThe date on which the company grants restricted stock to participants, which must be a trading day
Grant PriceThe price at which participants acquire company shares under the incentive plan
Lock-up PeriodThe period during which restricted stock cannot be transferred, pledged, or used to repay debts, starting from the registration date of the grant
Unlock PeriodThe period during which restricted stock may be unlocked and traded after meeting the conditions set by the plan
Unlock ConditionsConditions that must be met for the restricted stock to be unlocked
TermDefinition
Remuneration and Appraisal CommitteeThe Remuneration and Appraisal Committee under the Board of Directors
Company LawCompany Law of the People's Republic of China
Securities LawSecurities Law of the People's Republic of China
Administrative MeasuresAdministrative Measures on Equity Incentives of Listed Companies
Listing RulesRules Governing the Listing of Securities on the ChiNext Market of the Shenzhen Stock Exchange
Self-Regulatory Guidelines No. 1Shenzhen Stock Exchange ChiNext Market Self-Regulatory Guidelines No. 1 — Business Handling
Articles of AssociationArticles of Association of Shanghai Annoque Group Co., Ltd.
CSRCChina Securities Regulatory Commission
SZSEShenzhen Stock Exchange
Registration and Clearing CompanyChina Securities Depository and Clearing Corporation Limited, Shenzhen Branch
Our FirmBeijing Weiheng (Shanghai) Law Firm
Our LawyersThe signing lawyers of this legal opinion
Yuan, Ten Thousand YuanRMB Yuan, RMB Ten Thousand Yuan

To: Shanghai Annoque Group Co., Ltd.

Beijing Weiheng (Shanghai) Law Firm (hereinafter referred to as "our firm") has been engaged by Shanghai Annoque Group Co., Ltd. (hereinafter referred to as "Annoque" or the "Company") to serve as special legal counsel for the implementation of the 2026 Restricted Stock Incentive Plan (hereinafter referred to as the "Incentive Plan" or "this plan").

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