Jingtian & Gongcheng
Beijing, June 2026
To: Quantum Hi-Tech (China) Biological Co., Ltd.
Pursuant to the Legal Services Agreement signed between this firm and the Issuer, we have been engaged as the special legal counsel for this issuance.
Regarding this issuance, this firm issued the "Jingtian & Gongcheng Legal Opinion on the 2024 Issuance of Shares to Specific Targets by Quantum Hi-Tech (China) Biological Co., Ltd." (hereinafter referred to as the "Legal Opinion") and the "Jingtian & Gongcheng Lawyer's Work Report on the 2024 Issuance of Shares to Specific Targets by Quantum Hi-Tech (China) Biological Co., Ltd." (hereinafter referred to as the "Lawyer's Work Report") on August 20, 2025.
In view of the new facts and changes occurring between April 1, 2025, and June 30, 2025, and the "Quantum Hi-Tech (China) Biological Co., Ltd. 2025 Semi-Annual Report" disclosed by the Issuer on August 29, 2025, this firm issued the "Jingtian & Gongcheng Supplementary Legal Opinion (I) on the 2024 Issuance of Shares to Specific Targets by Quantum Hi-Tech (China) Biological Co., Ltd." (hereinafter referred to as "Supplementary Legal Opinion (I)") on September 12, 2025.
In accordance with the requirements of the "Audit Inquiry Letter on the Application for Issuance of Shares to Specific Targets by Quantum Hi-Tech (China) Biological Co., Ltd." (Audit Letter [2025] No. 020051) (hereinafter referred to as the "Audit Inquiry Letter") issued by the Listing Review Center of the Shenzhen Stock Exchange on September 16, 2025, this firm issued the "Jingtian & Gongcheng Supplementary Legal Opinion (II) on the 2024 Issuance of Shares to Specific Targets by Quantum Hi-Tech (China) Biological Co., Ltd." (hereinafter referred to as "Supplementary Legal Opinion (II)") on October 13, 2025.
Based on the facts and changes occurring during the period from July 1, 2025, to December 31, 2025 (the "Supplementary Period") and since the issuance of Supplementary Legal Opinion (I) and Supplementary Legal Opinion (II), as well as the "Quantum Hi-Tech (China) Biological Co., Ltd. 2025 Annual Report" (hereinafter referred to as the "2025 Annual Report") disclosed by the Issuer on April 29, 2026, this firm issued the "Jingtian & Gongcheng Supplementary Legal Opinion (III) on the 2024 Issuance of Shares to Specific Targets by Quantum Hi-Tech (China) Biological Co., Ltd." (hereinafter referred to as "Supplementary Legal Opinion (III)") on May 18, 2026.
According to the resolution passed at the 19th meeting of the 6th Board of Directors held on June 12, 2026, the Issuer has adjusted the issuance price and quantity for this offering. Based on further verification of the Issuer's relevant circumstances, this firm issues this supplementary legal opinion to amend, supplement, or further clarify the contents of the Legal Opinion, the Lawyer's Work Report, Supplementary Legal Opinion (I), Supplementary Legal Opinion (II), and Supplementary Legal Opinion (III). Regarding the Chinese domestic legal matters involved in the Audit Inquiry Letter, our lawyers, as legal professionals, have fulfilled their special duty of care. Regarding non-legal matters such as finance and accounting involved in the Audit Inquiry Letter, our lawyers, as non-financial professionals, have fulfilled their general duty of care, primarily relying on reviewing professional opinions issued by other professional institutions and interviewing relevant professionals.
Our lawyers consent to this supplementary legal opinion being used as a required statutory document for this issuance and submitted along with other materials, and assume corresponding legal responsibilities in accordance with the law. This supplementary legal opinion is for the sole purpose of the Issuer's current issuance and may not be used for any other purpose.
The statements made by our lawyers in the Legal Opinion and the Lawyer's Work Report also apply to this supplementary legal opinion. Unless otherwise specified, the terms used in this supplementary legal opinion have the same meanings as those in the Legal Opinion and the Lawyer's Work Report.