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Hunan Qiyuan Law Firm
Legal Opinion on the 2026 Restricted Stock Incentive Plan (Draft) of Hunan Huamin Holdings Group Co., Ltd.
July 2026
Address: 63rd Floor, Shimao Global Financial Center, 393 Jianxiang Road, Furong District, Changsha, 410007
Tel: (0731) 8295 3778 Fax: (0731) 8295 3779
Website: www.qiyuan.com
To: Hunan Huamin Holdings Group Co., Ltd.
Hunan Qiyuan Law Firm (hereinafter referred to as "Qiyuan" or "this Firm") has been engaged by Hunan Huamin Holdings Group Co., Ltd. (hereinafter referred to as "Huamin Holdings," "the Company," or "the Listed Company") to serve as special legal counsel for its 2026 Restricted Stock Incentive Plan (hereinafter referred to as "this Incentive Plan" or "the Incentive Plan").
This Firm has conducted an inspection and verification of the facts related to this Incentive Plan in accordance with the Company Law of the People's Republic of China (hereinafter "Company Law"), the Securities Law of the People's Republic of China (hereinafter "Securities Law"), the Administrative Measures for Equity Incentives of Listed Companies (hereinafter "Administrative Measures"), and other current laws, regulations, and normative documents, as well as the Articles of Association of Hunan Huamin Holdings Group Co., Ltd. (hereinafter "Articles of Association"), and in accordance with the business standards, ethical norms, and the spirit of diligence and responsibility generally recognized in the legal profession. We hereby issue this Legal Opinion of Hunan Qiyuan Law Firm on the 2026 Restricted Stock Incentive Plan of Hunan Huamin Holdings Group Co., Ltd. (hereinafter "this Legal Opinion").
This Firm (including the handling lawyers) declares as follows:
(1) This Firm issues legal opinions based on the laws, regulations, local government and departmental rules, normative documents of China, the relevant provisions of the China Securities Regulatory Commission and the stock exchange, and the facts that have occurred or existed prior to the date of issuance of this Legal Opinion.
(2) This Firm has strictly fulfilled its statutory duties, followed the principles of diligence, responsibility, and good faith, and has conducted sufficient inspection and verification of the Company's actions and the legality, compliance, truthfulness, and validity of this application, ensuring that this Legal Opinion contains no false records, misleading statements, or major omissions.
(3) This Firm's issuance of this legal opinion is based on the Company's guarantee to this Firm that the Company and its actual controllers, directors, other senior management personnel, and relevant natural persons have provided this Firm with all original written materials, copies, or oral testimonies that this Firm deems necessary for issuing this legal opinion, without concealment, falsehood, or major omissions, and that all signatures and/or seals on the materials are true and valid.
(4) When issuing this legal opinion, this Firm has fulfilled the special duty of care of a legal professional for legal matters, and has fulfilled the general duty of care of an ordinary person for non-legal matters such as accounting, evaluation, and credit rating.
(5) For facts that are crucial to this legal opinion but cannot be supported by independent evidence, this Firm issues opinions based on certificates issued by the Company, relevant government departments, and other relevant institutions, organizations, or individuals. For evidence materials obtained from state organs, organizations with the function of managing public affairs, accounting firms, and other independent third-party institutions, this Firm, after fulfilling its general duty of care, directly uses them as the basis for issuing this legal opinion. The citation of certain data and/or conclusions in relevant capital verification reports, audit reports, audited financial reports, review or appraisal reports, and other professional documents, as well as legal opinions issued by overseas lawyers in this legal opinion, does not mean that this Firm makes any express or implied guarantee or assumes joint and several liability for the truthfulness, accuracy, or completeness of such data or conclusions.