Legal Opinion from King & Wood Mallesons (Shenzhen) on the 2025 Annual Shareholders' Meeting of Sangfor Technologies Inc.
To: Sangfor Technologies Inc.
King & Wood Mallesons (Shenzhen) (hereinafter referred to as "our firm") has been entrusted by Sangfor Technologies Inc. (hereinafter referred to as "the Company") to issue this legal opinion in accordance with the Securities Law of the People's Republic of China (hereinafter referred to as "Securities Law"), the Company Law of the People's Republic of China (hereinafter referred to as "Company Law"), and the Rules for Shareholders' Meetings of Listed Companies issued by the China Securities Regulatory Commission (hereinafter referred to as "Shareholders' Meeting Rules"), as well as other relevant laws, administrative regulations, rules, normative documents, and the Company's Articles of Association currently in effect within the territory of the People's Republic of China (including the Hong Kong Special Administrative Region, the Macao Special Administrative Region, and Taiwan Province) (hereinafter referred to as "China"). For the purpose of issuing this legal opinion, our firm's lawyers attended the Company's 2025 Annual Shareholders' Meeting held on June 3, 2026 (hereinafter referred to as "this Shareholders' Meeting") and provided this legal opinion regarding matters related to this Shareholders' Meeting.
To issue this legal opinion, our firm's lawyers reviewed the following documents provided by the Company, including but not limited to:
- The Articles of Association of Sangfor Technologies Inc. approved at the Company's second extraordinary shareholders' meeting in 2025 (hereinafter referred to as "Articles of Association");
- Announcements of the resolutions from the 37th meeting of the third board of directors published on April 1, 2026, and the 39th meeting published on April 28, 2026, and the 40th meeting published on May 13, 2026, on the Giant Tide Information Network (http://www.cninfo.com.cn/) and the Shenzhen Stock Exchange website (https://www.szse.cn/);
- The notice for the 2025 Annual Shareholders' Meeting published on May 14, 2026 (hereinafter referred to as "Shareholders' Meeting Notice");
- The shareholder register as of the record date for this Shareholders' Meeting;
- Attendance records and supporting materials for shareholders present at the meeting;
- Statistical results of the online voting provided by Shenzhen Securities Information Co., Ltd.;
- Announcements and documents related to the proposals for this Shareholders' Meeting;
- Other meeting documents.
The Company has assured our firm that it has disclosed all facts that could affect the issuance of this legal opinion and provided all original written materials, copies, commitment letters, or certificates required by our firm for issuing this legal opinion, without any concealment, false statements, or significant omissions. The documents and materials provided by the Company are true, accurate, complete, and valid, and if the documents are copies or reproductions, they are consistent with the originals.
In this legal opinion, our firm only expresses opinions on the procedures for convening and holding this Shareholders' Meeting, the qualifications of the attendees, the qualifications of the convener, and whether the voting procedures and results comply with relevant laws, administrative regulations, the Shareholders' Meeting Rules, and the Articles of Association. Our firm does not express opinions on the content of the proposals reviewed at this Shareholders' Meeting or the truthfulness and accuracy of the facts or data presented in those proposals. Our firm only expresses opinions based on the currently effective laws and regulations within China and does not express opinions based on any foreign laws.