Beijing Jincheng Tongda (Xi'an) Law Firm
Legal Opinion
Regarding Xi'an Tianhe Defense Technology Co., Ltd.'s 2025 Annual Shareholders' Meeting
(2026) JTN (XA) Legal Document No. 0515118
To: Xi'an Tianhe Defense Technology Co., Ltd.
Beijing Jincheng Tongda (Xi'an) Law Firm (hereinafter referred to as "the Firm") was engaged by Xi'an Tianhe Defense Technology Co., Ltd. (hereinafter referred to as "Tianhe Defense" or "the Company") to appoint lawyer Zhang Hongyuan and lawyer Wang Jiaxin from the Firm to attend the 2025 Annual Shareholders' Meeting of the Company (hereinafter referred to as "the Meeting") and to issue a legal opinion on related matters.
The Firm's lawyers, in accordance with the requirements of laws, regulations, and normative documents such as 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," the "Rules for Shareholders' Meetings of Listed Companies" (hereinafter referred to as "Shareholders' Meeting Rules"), the "Administrative Measures for Law Firms Engaging in Securities Legal Business," and the "Practice Rules for Securities Legal Business of Law Firms (Trial)," as well as the provisions of the "Articles of Association of Xi'an Tianhe Defense Technology Co., Ltd." (hereinafter referred to as "Articles of Association"), have verified the convening and holding procedures of the Meeting, the qualifications of attendees, the qualifications of the convener, the voting procedures, and the voting results, and hereby issue this legal opinion.
Lawyers' Statement:
- The Firm's lawyers shall only express opinions on the legality of the convening and holding procedures of this Meeting, the qualifications of attendees, the qualifications of the convener, the voting procedures, and the voting results. They shall not express opinions on the authenticity, accuracy, and completeness of the facts or data stated in the proposals reviewed at this Meeting.
- The Firm's lawyers have, in accordance with the requirements of the "Shareholders' Meeting Rules," conducted checks and verifications on the relevant matters involved in this Meeting. The conclusions expressed are legal and accurate, and do not contain any false records, misleading statements, or significant omissions, and the Firm assumes corresponding legal responsibilities.
- The Firm's lawyers agree that this legal opinion will be disclosed together with other documents required for the Company's announcement of this Meeting.
- This legal opinion is for the sole purpose of the Company's Meeting and may not be used for any other purpose without the Firm's written consent.
The Firm's lawyers, in accordance with the generally accepted professional standards, ethical norms, and diligent and responsible spirit of the legal profession, issue the following legal opinions:
I. Convening and Holding Procedures of the Meeting
(I) Convening of the Meeting The Meeting was convened by the Board of Directors pursuant to a resolution of the Third Meeting of the Sixth Board of Directors of the Company.
On April 24, 2026, the Company's Board of Directors announced the "Notice of Xi'an Tianhe Defense Technology Co., Ltd. on Convening the 2025 Annual Shareholders' Meeting" (Announcement No.: 2026-010) on the Juchao Information Network and the Company's designated media. On April 28, 2026, it announced the "Announcement of Xi'an Tianhe Defense Technology Co., Ltd. on Adding Temporary Proposals and Supplementary Notice for the 2025 Annual Shareholders' Meeting" (Announcement No.: 2026-021) (hereinafter referred to as the "Meeting Notice"). The Meeting Notice specified the method of convening the Meeting, the time, place, online voting matters, items to be reviewed, attendees, and meeting registration methods.
(II) Holding of the Meeting The Meeting was held using a combination of on-site voting and online voting.
The on-site meeting was held at 15:30 on May 15, 2026, in the eighth-floor conference room of Xi'an Tianhe Defense Technology Co., Ltd., located at No. 158 West Section of West Second Road, High-tech Zone, Xi'an. The actual time and place of the on-site meeting were consistent with the time and place announced.