Zhejiang Tiance Law Firm
Supplementary Legal Opinion
Regarding Hangzhou High-Tech Materials Co., Ltd.'s 2026 Private Placement of A Shares
Supplementary Legal Opinion (I)
No.: TCYJS2026H1218
To: Hangzhou High-Tech Materials Co., Ltd.
Zhejiang Tiance Law Firm (hereinafter referred to as the "Firm") has been retained by Hangzhou High-Tech Materials Co., Ltd. (hereinafter referred to as the "Issuer," "Company," or "Hangzhou High-Tech") as its special legal advisor for the 2026 private placement of A shares (hereinafter referred to as the "Issuance" or "This Private Placement"). The Firm has previously issued the "Zhejiang Tiance Law Firm's Legal Opinion on Hangzhou High-Tech Materials Co., Ltd.'s 2026 Private Placement of A Shares" (hereinafter referred to as the "Legal Opinion") with No. TCYJS2026H0823 and the "Zhejiang Tiance Law Firm's Lawyer's Work Report on Hangzhou High-Tech Materials Co., Ltd.'s 2026 Private Placement of A Shares" (hereinafter referred to as the "Work Report").
On July 6, 2026, the Shenzhen Stock Exchange (hereinafter referred to as the "SZSE") issued the "Inquiry Letter Regarding Hangzhou High-Tech Materials Co., Ltd.'s Application for Private Placement of Shares" (hereinafter referred to as the "Inquiry Letter") with No. [2026] 020055, requesting the Issuer and intermediary institutions to provide explanations and clarifications on relevant issues.
In accordance with the SZSE's requirements, the Firm's lawyers have investigated the matters raised in the "Inquiry Letter" in accordance with relevant laws and regulations, and the generally accepted professional standards, ethical norms, and diligence requirements of the legal profession, and hereby issue this Supplementary Legal Opinion (hereinafter referred to as this "Supplementary Legal Opinion").
The Firm and its handling lawyers, in accordance with the "Securities Law of the People's Republic of China," the "Administrative Measures for Securities Legal Business of Law Firms," the "Practice Rules for Securities Legal Business of Law Firms (Trial)," and other relevant regulations, and based on facts that have occurred or existed prior to the issuance of this Supplementary Legal Opinion, 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 determined in this Supplementary 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 significant omissions, and shall bear corresponding legal liabilities.
Except as otherwise defined in this Supplementary Legal Opinion or as otherwise indicated by the context, the basis for issuance, lawyer's statement, definitions, and explanations set forth in the "Legal Opinion" and the "Work Report" shall apply to this Supplementary Legal Opinion.
I. The application materials show that the Issuer intends to conduct a private placement of no more than 9,760,858 shares to its controlling shareholder, Beijing Jubilant Great Wall Energy Technology Co., Ltd. (hereinafter referred to as "Jubilant Great Wall"), with an issue size not exceeding RMB 150 million. After deducting relevant issuance expenses, the funds will be used to repay loans and supplement working capital. Upon completion of the issuance, Jubilant Great Wall's shareholding ratio will increase from 19.03% to 24.82%. Jubilant Great Wall has pledged that the shares subscribed in this private placement will be locked up for 18 months. On August 8, 2025, Donghang Group, Jubilant Great Wall, Hu Min, and Jubilant Energy (Xinjiang) Co., Ltd. signed a share transfer agreement, whereby Donghang Group agreed to transfer its 24,105,872 shares in the Issuer to Jubilant Great Wall through an agreement transfer, representing 19.03% of the Issuer's total share capital.