Shanghai Landing Law Firm
Legal Opinion on the Adjustment and Grant of Restricted Stock for Kunlun Wanwei Technology Co., Ltd.'s 2026 Restricted Stock Incentive Plan
To: Kunlun Wanwei Technology Co., Ltd.
Shanghai Landing Law Firm has been entrusted by Kunlun Wanwei Technology Co., Ltd. (hereinafter referred to as "Kunlun Wanwei" or "the Company", stock code 300418) to issue this legal opinion on matters related to the Company's implementation of the 2026 Restricted Stock Incentive Plan.
In accordance with the "Company Law of the People's Republic of China," "Securities Law of the People's Republic of China," "Administrative Measures for Equity Incentives of Listed Companies," "Shenzhen Stock Exchange GEM Stock Listing Rules," and "Shenzhen Stock Exchange GEM Listed Company Self-Regulatory Guidance No. 1 - Business Handling," as well as other relevant laws, regulations, normative documents, and the "Articles of Association of Kunlun Wanwei Technology Co., Ltd.," and in accordance with the generally recognized business standards, ethical norms, and the principle of diligence and responsibility of the legal profession, our firm issued the "Legal Opinion on the Draft 2026 Restricted Stock Incentive Plan of Kunlun Wanwei Technology Co., Ltd." (hereinafter referred to as the "Draft Legal Opinion") on March 27, 2026. This legal opinion is hereby issued regarding the adjustment and grant of restricted stock under this incentive plan.
In order to issue this legal opinion, our firm hereby makes the following statements:
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In accordance with the "Securities Law of the People's Republic of China," the "Administrative Measures for Securities Legal Business of Law Firms," and the "Practice Rules for Securities Legal Business of Law Firms (Trial)," and based on facts that have occurred or existed prior to the issuance date of this legal opinion, our firm's lawyers have strictly performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough investigations and verifications, and ensured that the facts identified in this legal opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, and do not contain any false records, misleading statements, or major omissions, and we assume corresponding legal responsibilities.
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This legal opinion shall be used in conjunction with the "Draft Legal Opinion." Unless otherwise specified, the abbreviations used in this legal opinion shall have the same meaning as in the "Draft Legal Opinion." The premises, assumptions, and statements made by our firm in the "Draft Legal Opinion" are equally applicable to this legal opinion.
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Our firm agrees that Kunlun Wanwei may use this legal opinion as one of the essential legal documents for the implementation of the 2026 Restricted Stock Incentive Plan, and will submit it along with other application materials to the Shenzhen Stock Exchange for public disclosure, and is willing to assume corresponding legal responsibilities according to law.
Main Text
I. Regarding the Approval and Authorization for the Implementation of the "2026 Restricted Stock Incentive Plan" and the Grant of Shares
- On March 27, 2026, the first meeting of the Compensation and Assessment Committee of the Fifth Board of Directors of Kunlun Wanwei in 2026 deliberated and passed the "Proposal on the Draft 2026 Restricted Stock Incentive Plan and its Summary," the "Proposal on the Implementation and Assessment Management Measures for the 2026 Restricted Stock Incentive Plan," and the "Proposal on Verifying the List of Incentive Recipients for the 2026 Restricted Stock Incentive Plan."
On March 27, 2026, the 38th meeting of the Fifth Board of Directors of Kunlun Wanwei deliberated and passed the "Proposal on the Draft 2026 Restricted Stock Incentive Plan and its Summary," the "Proposal on the Implementation and Assessment Management Measures for the 2026 Restricted Stock Incentive Plan," and the "Proposal to Request the Shareholders' Meeting to Authorize the Board of Directors to Handle Matters Related to the 2026 Restricted Stock Incentive Plan." No independent directors needed to recuse themselves from voting on the aforementioned proposals.