HeBei JiHua Law Firm
Legal Opinion on the 2025 Annual Shareholders' Meeting of Hebei Huijin Group Co., Ltd.
To: Hebei Huijin Group Co., Ltd.
2025 Jihua (Gu) No. 306
Hebei Jihua Law Firm was entrusted by Hebei Huijin Group Co., Ltd. (hereinafter referred to as "the Company" or "Huijin Shares") to appoint lawyers to attend and witness the 2025 Annual Shareholders' Meeting (hereinafter referred to as "the Meeting") held by the Company on May 18, 2026, and hereby issues this Legal Opinion in accordance with the "Company Law of the People's Republic of China" (hereinafter referred to as "Company Law"), the "Securities Law of the People's Republic of China" (hereinafter referred to as "Securities Law"), the "Rules of the Shareholders' Meeting of Listed Companies" (hereinafter referred to as "Rules"), and the "Articles of Association of Hebei Huijin Group Co., Ltd." (hereinafter referred to as "Articles of Association").
To issue this Legal Opinion, the lawyers of this firm have examined the relevant matters involved in the Meeting, reviewed the documents that the lawyers of this firm deem necessary for issuing this Legal Opinion, and conducted necessary verifications and confirmations.
The Company has guaranteed and promised to the lawyers of this firm that the documents provided and the statements and explanations made by the Company are true, accurate, complete, and effective, without any concealment, falsification, or major omissions, and that the documents are consistent with their originals if they are copies or duplicates.
This Legal Opinion is for the sole purpose of the Company's Meeting and shall not be used by any person for any other purpose without the written consent of this firm. This firm agrees that the Company may use this Legal Opinion as part of the announcement materials for the Meeting, along with other information to be announced to the public, and this firm shall bear corresponding legal responsibilities for the legal opinion issued by this firm.
In accordance with the requirements of the "Securities Law" and "Company Law," the lawyers of this firm, in accordance with the generally accepted business standards, ethical norms, and diligence spirit of the legal profession, have verified the relevant facts of the Meeting and the documents provided by the Company, and attended the Meeting. The legal opinion is hereby issued as follows:
I. Convening and Holding Procedures of the Meeting
-
Upon examination by the lawyers of this firm, the Company published the "Notice on Convening the 2025 Annual Shareholders' Meeting" on the Juchao Information Network on April 25, 2026.
-
According to the meeting notice, the Meeting adopted a voting method that combined on-site voting and online voting.
-
The Meeting was presided over by Mr. Mao Shiquan, Chairman of the Company, in the Company's conference room on May 18, 2026. The online voting time through the Shenzhen Stock Exchange trading system was 9:15-9:25, 9:30-11:30 in the morning and 13:00-15:00 in the afternoon on May 18, 2026; the online voting time through the Shenzhen Stock Exchange Internet Voting System (http://wltp.cninfo.com.cn) was any time between 9:15 and 15:00 on May 18, 2026.
The lawyers of this firm believe that the time, place, and content of the Meeting are consistent with the announcement, and the convening and holding of the Meeting comply with the relevant provisions of laws, regulations, normative documents, and the Articles of Association.
II. Qualifications of Attendees and Convener of the Meeting