Hunan Qiyuan Law Firm
Changsha City, Furong District, Jianxiang Road 393, Shimao Global Financial Center, 63rd Floor, 410000
Tel: (0731) 8295 3778
Fax: (0731) 8295 3779
http://www.qiyuan.com
Legal Opinion from Hunan Qiyuan Law Firm on Jiangsu Guangxin Photonic New Materials Co., Ltd. 2025 Annual Shareholders' Meeting
To: Jiangsu Guangxin Photonic New Materials Co., Ltd.
Hunan Qiyuan Law Firm (hereinafter referred to as "this Firm") is entrusted by Jiangsu Guangxin Photonic New Materials Co., Ltd. (hereinafter referred to as "the Company") to witness the on-site proceedings 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 Rules for Shareholders' Meetings of Listed Companies (hereinafter referred to as "the Meeting Rules"), the Implementation Rules for Online Voting at Shareholders' Meetings of Listed Companies on the Shenzhen Stock Exchange (hereinafter referred to as "the Online Voting Implementation Rules"), and other relevant laws, regulations, normative documents, as well as the Articles of Association of Jiangsu Guangxin Photonic New Materials Co., Ltd. (hereinafter referred to as "the Articles of Association").
To issue this legal opinion, this Firm appointed its lawyers to attend this Shareholders' Meeting, and in accordance with the recognized business standards, ethical norms, and diligent spirit of the legal profession, witnessed the proceedings of this Shareholders' Meeting, and verified the documents, materials, and facts provided by the Company related to this Shareholders' Meeting. This Firm issues this legal opinion based on the Company's assurance that it has provided all necessary materials and information for the issuance of this legal opinion, and that all facts and materials that could affect this legal opinion have been disclosed to this Firm; all materials provided by the Company are true, accurate, and complete, with no false records, misleading statements, or significant omissions, and all signatures and/or seals on the materials are true and valid, with copies or reproductions consistent with the originals.
This legal opinion only expresses opinions on the legality and validity of the convening and holding procedures of this Shareholders' Meeting, the qualifications of the convener and attendees, the voting procedures, and the voting results, as required by Article 6 of the Meeting Rules, and does not express opinions on the content of the proposals reviewed at this Shareholders' Meeting or the truthfulness, accuracy, completeness, legality, or validity of the facts or data described therein. This legal opinion is solely for the purpose of witnessing this Shareholders' Meeting, and this Firm agrees that the Company may announce this legal opinion together with other documents of this Shareholders' Meeting in accordance with relevant regulations. Without this Firm's written consent, this legal opinion shall not be used for any other purpose or use.
I. Procedures for Convening and Holding this Shareholders' Meeting
- On April 27, 2026, the 21st meeting of the 5th Board of Directors of the Company reviewed and approved the proposal to convene the 2025 Annual Shareholders' Meeting.
- On April 29, 2026, the Company's Board of Directors announced the notice of this Shareholders' Meeting in the media designated by the China Securities Regulatory Commission and on the Giant Tide Information website, detailing the convener, time, location, method of convening, proposals, attendees, and registration methods, with the record date for shareholding set for May 27, 2026.
- This Shareholders' Meeting will be held using a combination of on-site voting and online voting. Online voting will be conducted through the Shenzhen Stock Exchange trading system and the internet voting system, with specific times for online voting through the Shenzhen Stock Exchange trading system set for June 2, 2026, from 9:15 to 9:25, 9:30 to 11:30, and 13:00 to 15:00; and for the internet voting system from June 2, 2026, 09:15 to 15:00. The on-site meeting will be held on June 2, 2026 (Tuesday) at 14:30, with the meeting time, location, and proposals consistent with the notice of the 2025 Annual Shareholders' Meeting. The end time of the on-site meeting will be later than the online voting.