Kangda Law Firm
Legal Opinion
Beijing Kangda (Shenzhen) Law Firm
Regarding Guangzhou Haozhi Electromechanical Co., Ltd.'s 2024 Restricted Stock Incentive Plan: Adjustment of Grant Price, Fulfillment of Vesting Conditions for the Second Tranche of the Initial Grant and the First Tranche of the Reserved Grant, and Forfeiture of Certain Restricted Shares
Kangda (Shenzhen) Legal Opinion [2026] No. 0033
To: Guangzhou Haozhi Electromechanical Co., Ltd.
Beijing Kangda (Shenzhen) Law Firm (hereinafter referred to as "the Firm") has been appointed by Guangzhou Haozhi Electromechanical Co., Ltd. (hereinafter referred to as "Haozhi Electromechanical" or "the Company") as the special legal advisor for the Company's 2024 Restricted Stock Incentive Plan (hereinafter referred to as "the Plan"). This opinion addresses the adjustment of the grant price under the Plan (hereinafter referred to as "the Adjustment"), the fulfillment of vesting conditions for the second tranche of the initial grant and the first tranche of the reserved grant (hereinafter referred to as "the Vesting"), and the forfeiture of certain granted but unvested restricted shares (hereinafter referred to as "the Forfeiture"). In accordance with the Company Law of the People's Republic of China (hereinafter referred to as "the Company Law"), the Securities Law of the People's Republic of China (hereinafter referred to as "the Securities Law"), the Measures for the Administration of Equity Incentives of Listed Companies (2025 Revision) (hereinafter referred to as "the Administration Measures"), the Shenzhen Stock Exchange GEM Stock Listing Rules (2026 Revision) (hereinafter referred to as "the Listing Rules"), the Shenzhen Stock Exchange GEM Listed Company Self-Regulatory Supervision Guidelines No. 1 - Business Handling (hereinafter referred to as "the Supervision Guidelines"), and other relevant national laws, regulations, and normative documents, and adhering to the business standards, ethical norms, and diligence principles recognized by the legal profession, this Legal Opinion is hereby issued.
The Firm's lawyers solely rely on the facts that have occurred or existed prior to the issuance date of this Legal Opinion, and the provisions of the Company Law, the Securities Law, the Administration Measures, the Listing Rules, the Supervision Guidelines, and other current laws, regulations, and normative documents to express legal opinions. For facts that are crucial to this Legal Opinion but cannot be independently verified, the Firm relies on the statements and assurances of the Company and other relevant parties.
This Legal Opinion is solely for the purpose of the Company's incentive plan matters and shall not be used for any other purpose. The Firm's lawyers agree that this Legal Opinion may be used as a necessary legal document for the Company's implementation of this incentive plan, along with other materials submitted for reporting. The Firm's lawyers agree that the Company may quote or cite parts or all of this Legal Opinion, provided that such quotation or citation does not cause legal ambiguity or misinterpretation.
To issue this Legal Opinion, the Firm's lawyers have reviewed and copied the documents and materials required for its preparation. The Company has provided assurances to the Firm that all statements, documents, and materials provided to the Firm are true, complete, accurate, and free from any false statements, material omissions, or misleading statements, and that the copies of relevant documents and materials are consistent with the originals.
The Firm's lawyers have strictly performed their statutory duties, adhered to the principles of diligence and good faith, and conducted a thorough investigation and verification of the legality, compliance, and authenticity of the Company's implementation of the incentive plan, and based on this, have issued this legal opinion. This Legal Opinion does not contain any false records, misleading statements, or material omissions.
After reviewing and verifying the relevant documents and materials, the Firm's lawyers, in accordance with the business standards, ethical norms, and diligence principles recognized by the legal profession, issue the following legal opinion: