TIANYUAN LAW FIRM
Beijing Tian Yuan Law Firm Legal Opinion on Kunlun Tech Co., Ltd.'s 2026 Second Extraordinary General Meeting
Jing Tian Gu Zi (2026) No. 139
To: Kunlun Tech Co., Ltd.
Kunlun Tech Co., Ltd. (hereinafter referred to as the "Company") convened its 2026 Second Extraordinary General Meeting (hereinafter referred to as the "Meeting") using a combination of on-site and online voting. The on-site meeting was held on April 13, 2026, in Conference Room 11, Block B, Mingyang International Center, No. 46 Xibushou Hutong, Dongcheng District, Beijing.
Beijing Tian Yuan Law Firm (hereinafter referred to as the "Firm") was appointed by the Company to send lawyers to attend the on-site meeting. Based on the "Company Law of the People's Republic of China," the "Securities Law of the People's Republic of China" (hereinafter referred to as the "Securities Law"), the "Rules for Shareholders' Meetings of Listed Companies" (hereinafter referred to as the "Shareholders' Meeting Rules"), and the "Articles of Association of Kunlun Tech Co., Ltd." (hereinafter referred to as the "Articles of Association"), the Firm hereby issues this legal opinion on the convening and holding procedures, qualifications of attendees, convener qualifications, voting procedures, and voting results of the Meeting.
To issue this legal opinion, the Firm's lawyers have reviewed the "Announcement of the Resolution of the Thirty-Eighth Meeting of the Fifth Board of Directors of Kunlun Tech Co., Ltd." and the "Announcement of Kunlun Tech Co., Ltd. on Convening the 2026 Second Extraordinary General Meeting" (hereinafter referred to as the "Notice of Meeting"), as well as other documents and materials deemed necessary by the Firm's lawyers. Additionally, they have verified the identity and qualifications of the shareholders attending the on-site meeting, witnessed the convening of the Meeting, and participated in the counting and supervision of votes for the proposals at the Meeting.
The Firm and the handling lawyers have fulfilled their statutory duties in accordance with the "Securities Law," the "Administrative Measures for Law Firms Engaging in Securities Legal Business," and the "Practice Rules for Law Firms Engaging in Securities Legal Business (Trial)," and based on facts that have occurred or existed prior to the issuance date of this legal opinion. They have adhered to the principles of diligence, conscientiousness, and good faith, and have conducted thorough verification and inspection to ensure that the facts identified in this legal opinion are true, accurate, and complete, and that the conclusions expressed are legal, accurate, and free from any false records, misleading statements, or material omissions, and they bear corresponding legal responsibilities.
The Firm and the handling lawyers agree that this legal opinion will be used as a statutory document for the announcement of the Meeting, to be submitted to the Shenzhen Stock Exchange (hereinafter referred to as the "SZSE") for review and announcement along with other announcement documents, and they will bear legal responsibility for the issuance of this legal opinion.
The Firm's lawyers have, in accordance with the generally accepted professional standards, ethical norms, and the spirit of diligence and conscientiousness in the legal profession, inspected and verified the documents and relevant facts provided by the Company, and hereby issue the legal opinion as follows: