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Jincheng Tongda & Neal Law Firm
Regarding
Xi'an Tianhe Defense Technology Co., Ltd.
2024 Issuance of Shares to Specific Targets
Supplementary Legal Opinion (II)
Jinzheng Fayi [2026] No. 0512-0314
Beijing Jincheng Tongda & Neal Law Firm
To: Xi'an Tianhe Defense Technology Co., Ltd.
Our firm has been engaged by the Issuer as special legal counsel for this issuance to provide legal services. In accordance with the Securities Law, the Company Law, the Administrative Measures for the Issuance of Securities, the Listing Rules, and the Compilation Rules for Information Disclosure by Companies Offering Securities to the Public No. 12—Legal Opinion and Lawyer's Work Report, and following recognized professional standards, ethical norms, and the principle of diligence, we have examined the documents and facts provided by the Issuer to issue this legal opinion.
Our firm issued the "Lawyer's Work Report of Beijing Jincheng Tongda & Neal Law Firm on the 2024 Issuance of Shares to Specific Targets by Xi'an Tianhe Defense Technology Co., Ltd." (hereinafter referred to as the "Lawyer's Work Report") and the "Legal Opinion of Beijing Jincheng Tongda & Neal Law Firm on the 2024 Issuance of Shares to Specific Targets by Xi'an Tianhe Defense Technology Co., Ltd." (hereinafter referred to as the "Legal Opinion") on October 22, 2025. Regarding the feedback from the exchange, our firm issued the "Supplementary Legal Opinion (I) of Beijing Jincheng Tongda & Neal Law Firm on the 2024 Issuance of Shares to Specific Targets by Xi'an Tianhe Defense Technology Co., Ltd." on December 5, 2025. Given the Issuer's update of its 2025 financial report, our firm issued the "Supplementary Legal Opinion (II) of Beijing Jincheng Tongda & Neal Law Firm on the 2024 Issuance of Shares to Specific Targets by Xi'an Tianhe Defense Technology Co., Ltd." on May 13, 2026, to conduct supplementary verification of major matters concerning the Issuer during the period from October 22, 2025, to May 13, 2026 (hereinafter referred to as the "Supplementary Verification Period").
Based on further review requirements from the Shenzhen Stock Exchange and additional verification of the Issuer's issuance and listing status, we hereby issue this "Supplementary Legal Opinion (II) of Beijing Jincheng Tongda & Neal Law Firm on the 2024 Issuance of Shares to Specific Targets by Xi'an Tianhe Defense Technology Co., Ltd." (Revised Edition) (hereinafter referred to as this "Supplementary Legal Opinion"), to modify, supplement, or further clarify the contents of the previously issued Legal Opinion and Lawyer's Work Report. The "Reporting Period" mentioned in this Supplementary Legal Opinion refers to the years 2023, 2024, and 2025.
Unless otherwise specified, the terms, names, and abbreviations used in this Supplementary Legal Opinion have the same meanings as those in the Legal Opinion and the Lawyer's Work Report. The declarations made by our firm in the Legal Opinion and the Lawyer's Work Report apply to this Supplementary Legal Opinion. This Supplementary Legal Opinion constitutes a necessary supplement to the Legal Opinion and the Lawyer's Work Report. In case of any inconsistency between the Legal Opinion, the Lawyer's Work Report, and this Supplementary Legal Opinion, this Supplementary Legal Opinion shall prevail. Except for the contents of this Supplementary Legal Opinion, the opinions and conclusions of our firm regarding other legal issues of the Issuer's issuance remain subject to the relevant statements in the Legal Opinion and the Lawyer's Work Report.
Our firm agrees to submit this Supplementary Legal Opinion as a required legal document for the Issuer's issuance along with other materials and assumes legal responsibility for this Supplementary Legal Opinion in accordance with the law.