Kangda Law Firm KANGDA LAW FIRM Legal Opinion
8/9/11/F, Emperor Group Centre, No.12D, Jianwai Avenue, Chaoyang District, Beijing, 100022, P.R.China Tel.:010-50867666 Fax:010-56916450 Website:www.kangdalawyers.com Beijing Xi'an Shenzhen Haikou Shanghai Guangzhou Hangzhou Shenyang Nanjing Tianjin Heze Chengdu Suzhou Hohhot Hong Kong Wuhan Zhengzhou Changsha Xiamen Chongqing Hefei Ningbo Jinan
Legal Opinion of Kangda Law Firm on Beijing Digital City Technology Co., Ltd.'s 2026 Second Extraordinary General Meeting
To: Beijing Digital City Technology Co., Ltd. Kangda Shareholder Meeting Letter [2026] No. [0047]
Pursuant to the "Company Law of the People's Republic of China" (hereinafter referred to as the "Company Law"), the "Rules for Shareholders' Meetings of Listed Companies" (hereinafter referred to as the "Rules"), the "Shenzhen Stock Exchange Listed Company Shareholders' Meeting Online Voting Implementation Rules" (hereinafter referred to as the "Implementation Rules"), the Articles of Association of Beijing Digital City Technology Co., Ltd. (hereinafter referred to as the "Articles of Association"), and the "Legal Advisor Agreement" signed between Beijing Digital City Technology Co., Ltd. (hereinafter referred to as the "Company") and Kangda Law Firm (hereinafter referred to as the "Firm"), the Firm's lawyers were engaged to attend the Company's 2026 Second Extraordinary General Meeting (hereinafter referred to as the "Meeting") and hereby issue this Legal Opinion.
In order to issue this Legal Opinion, the Firm's lawyers make the following statements:
-
The legal opinions expressed by the Firm's lawyers are formed based on facts that occurred or existed prior to the issuance date of this Legal Opinion and based on the Firm's lawyers' understanding of relevant laws, regulations, and normative documents. In this Legal Opinion, the Firm's lawyers will only express legal opinions after reviewing and witnessing the procedures for convening and holding the Meeting, the qualifications of the attendees and the convener, and the voting procedures and results of the Meeting. The Firm's lawyers will not express opinions on the truthfulness and accuracy of the content of the proposals deliberated at the Meeting or the facts and data involved in the proposals.
-
The Firm's lawyers have expressed legal opinions on the authenticity and legality of the Company's Meeting in accordance with the requirements of the "Company Law," the "Rules," and the "Articles of Association." The legal opinion contains no false or misleading statements or material omissions; otherwise, they shall bear corresponding legal liabilities.
-
The Firm's lawyers agree to use this Legal Opinion as an official document for the Company's Meeting announcement and shall bear legal responsibility for the legal opinions issued by the Firm.
The Firm's lawyers have reviewed all documents and materials related to the issuance of this Legal Opinion and have witnessed the on-site meeting of this Shareholders' Meeting and hereby issue the legal opinion as follows:
I. Convening and Holding Procedures of the Meeting
(I) Convening of the Meeting
The Meeting was convened by the Company's Board of Directors. According to the announcement titled "Notice of Beijing Digital City Technology Co., Ltd. on Convening the 2026 Second Extraordinary General Meeting" published on the Investor Relations website (http://www.cninfo.com.cn), the Company's Board of Directors issued the notice for convening this Meeting on February 28, 2026.