Legal Opinion of Henan Shengpin Law Firm
To: Jilin Jin Guan Electric Co., Ltd.
Henan Shengpin Law Firm (hereinafter referred to as "this Firm") has been entrusted by Jilin Jin Guan Electric Co., Ltd. (hereinafter referred to as "Jin Guan Shares" or "the Company") to appoint lawyers from this Firm to witness the relevant matters of the Company's 2025 Annual Shareholders' Meeting (hereinafter referred to as "this Shareholders' Meeting") and to issue this legal opinion 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 Rules for Shareholders' Meetings of Listed Companies (hereinafter referred to as "the Shareholders' Meeting Rules"), and other relevant laws, regulations, and normative documents, as well as the provisions of the Articles of Association of Jilin Jin Guan Electric Co., Ltd. (hereinafter referred to as "the Articles of Association"). This opinion addresses the convening and holding procedures of this Shareholders' Meeting, the qualifications of the convener, the qualifications of attendees, the voting procedures, and the voting results.
The lawyers of this Firm make the following statements regarding the issuance of this legal opinion:
- The lawyers of this Firm only express opinions on the legality of the convening and holding procedures of this Shareholders' Meeting, the qualifications of the convener and attendees, the voting procedures, and the voting results, and do not express opinions on the content of the proposals reviewed at this Shareholders' Meeting or the truthfulness, accuracy, and completeness of the facts or data presented in such proposals.
- This Firm's lawyers are unable to witness the online voting process; the qualifications of shareholders participating in the online voting and the results of the online voting are certified by the respective securities exchange trading system and internet voting system.
- The lawyers of this Firm have conducted necessary verification and validation of the relevant matters involved in this Shareholders' Meeting in accordance with the requirements of the Shareholders' Meeting Rules, and the conclusive opinions expressed are legal and accurate, with no false records, misleading statements, or significant omissions.
- This legal opinion is only for the purpose of this Shareholders' Meeting and shall not be used for any other purpose. The lawyers of this Firm agree to submit this legal opinion along with other information disclosure materials for this Shareholders' Meeting to the Shenzhen Stock Exchange (hereinafter referred to as "SZSE") for review and announcement.
The lawyers of this Firm have strictly fulfilled their statutory duties in accordance with the aforementioned laws, administrative regulations, rules, normative documents, and the relevant provisions of the Articles of Association, as well as the facts that have occurred or existed prior to the issuance date of this legal opinion. They have adhered to the principles of diligence and good faith, conducted sufficient verification of the relevant matters of this Shareholders' Meeting, and ensured that the facts recognized in this legal opinion are true, accurate, and complete. The conclusive opinions expressed in this legal opinion are legal and accurate, with no false records, misleading statements, or significant omissions, and the Firm bears corresponding legal responsibilities.
I. The Convening and Holding Procedures of this Shareholders' Meeting
(1) The Convening of this Shareholders' Meeting
This Shareholders' Meeting is proposed and convened by the Board of Directors. On April 26, 2026, the Company's Board of Directors held the eighth meeting of the seventh Board of Directors and resolved to convene this Shareholders' Meeting. According to the notice titled "Notice of the 2025 Annual Shareholders' Meeting of Jilin Jin Guan Electric Co., Ltd." announced on April 28, 2026 (Announcement No.: 2026-014), the Company intends to hold the 2025 Annual Shareholders' Meeting at 14:00 on May 26, 2026, through a combination of on-site voting and online voting. The Board of Directors notified all shareholders of this meeting on April 28, 2026, and the notice included the matters to be reviewed at this Shareholders' Meeting (Giant Tide Information Network www.cninfo.com.cn).