Grandway Law Offices
Legal Opinion on the 2026 Restricted Stock Incentive Plan (Draft) of Eoptolink Technology Inc., Ltd.
Grandway Legal Opinion [2026] No. AN177-1
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7th Floor, News Plaza, 26 Jianguomennei Avenue, Dongcheng District, Beijing, 100005
Tel: 010-88004488/66090088 Fax: 010-66090016
Table of Contents
Definitions 2
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Subject Eligibility for the Incentive Plan 4
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Legality and Compliance of the Incentive Plan's Main Content 6
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Statutory Procedures Involved in the Incentive Plan 16
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Participants of the Incentive Plan 18
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Information Disclosure of the Incentive Plan 19
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Absence of Financial Assistance to Participants 19
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Impact of the Incentive Plan on the Company and Shareholders' Interests 20
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Recusal of Interested Directors 20
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Conclusion 21
Definitions
In this legal opinion, unless the context otherwise requires, the following terms or abbreviations have the following meanings:
| Term | Definition |
|---|---|
| Eoptolink / Company | Eoptolink Technology Inc., Ltd. |
| Incentive Plan, This Plan | Eoptolink Technology Inc., Ltd. 2026 Restricted Stock Incentive Plan |
| Incentive Plan (Draft) | Eoptolink Technology Inc., Ltd. 2026 Restricted Stock Incentive Plan (Draft) |
| Assessment Measures | Eoptolink Technology Inc., Ltd. 2026 Restricted Stock Incentive Plan Implementation Assessment Measures |
| Restricted Stock, Type II Restricted Stock | Company stock obtained and registered by eligible participants in installments after meeting vesting conditions |
| Participants | Directors, senior management, middle management, core technical/business personnel, and others deemed necessary by the Board |
| Audit Report | Tianjian Audit [2026] No. 3-249 "Eoptolink Technology Inc., Ltd. 2025 Annual Audit Report" issued by Pan-China Certified Public Accountants (Special General Partnership) |
| Company Law | Company Law of the People's Republic of China |
| Securities Law | Securities Law of the People's Republic of China |
| Administrative Measures | Administrative Measures for Equity Incentives of Listed Companies |
| Listing Rules | Rules Governing the Listing of Stocks on the ChiNext Market of the Shenzhen Stock Exchange |
| Regulatory Guidelines | Shenzhen Stock Exchange ChiNext Listed Company Self-Regulatory Guidelines No. 1 — Business Handling |
| Articles of Association | Articles of Association of Eoptolink Technology Inc., Ltd. |
| CSRC | China Securities Regulatory Commission |
| SZSE | Shenzhen Stock Exchange |
| This Firm | Grandway Law Offices |
| Yuan, Ten Thousand Yuan | RMB Yuan, RMB Ten Thousand Yuan |
To: Eoptolink Technology Inc., Ltd.
Pursuant to the "Legal Services Agreement" signed between this firm and Eoptolink, this firm has been engaged as the special legal counsel for the company's incentive plan. We have issued this legal opinion in accordance with the Company Law, Securities Law, Administrative Measures, Regulatory Guidelines, and other relevant laws, regulations, and the Articles of Association, following professional standards and the principle of due diligence.
We hereby make the following declarations:
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This firm expresses legal opinions only on facts that have occurred or existed prior to the date of this legal opinion, based on currently effective Chinese laws and regulations.
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In accordance with the Securities Law and relevant professional rules, this firm has performed its statutory duties with due diligence and good faith, conducted sufficient verification, and ensures that the facts recognized are true, accurate, and complete, and that the conclusions reached are legal and accurate.
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This legal opinion is intended solely for the purpose of implementing the incentive plan and shall not be used for any other purpose. We consent to the inclusion of this legal opinion as a required statutory document for the incentive plan.