Supplementary Legal Opinion of Beijing King & Wood Mallesons on Nanjing Sanchao New Materials Co., Ltd.'s 2025 A-Share Issuance (I)
To: Nanjing Sanchao New Materials Co., Ltd.
Beijing King & Wood Mallesons (hereinafter referred to as "our firm") has been entrusted by Nanjing Sanchao New Materials Co., Ltd. (hereinafter referred to as "the issuer") to act as the special legal advisor for the issuer's 2025 A-share issuance to specific investors (hereinafter referred to as "this issuance"). Our firm has issued the "Legal Opinion on Nanjing Sanchao New Materials Co., Ltd.'s 2025 A-Share Issuance to Specific Investors" (hereinafter referred to as "the Legal Opinion") and the "Lawyer's Work Report on Nanjing Sanchao New Materials Co., Ltd.'s 2025 A-Share Issuance to Specific Investors" (hereinafter referred to as "the Lawyer's Work Report") on April 17, 2026, in accordance with the "Securities Law of the People's Republic of China" (hereinafter referred to as "the Securities Law"), "Company Law of the People's Republic of China" (hereinafter referred to as "the Company Law"), "Regulations on the Registration of Securities Issuance by Listed Companies" (hereinafter referred to as "the Registration Regulations"), "Shenzhen Stock Exchange GEM Listing Rules" (hereinafter referred to as "the GEM Listing Rules"), "Management Measures for Law Firms Engaging in Securities Legal Business" (hereinafter referred to as "the Securities Legal Business Management Measures"), "Trial Implementation Rules for Law Firms' Securities Legal Business" (hereinafter referred to as "the Securities Legal Business Practice Rules"), and "Guidelines for the Compilation of Information Disclosure by Publicly Issuing Securities Companies No. 12 - Legal Opinions and Lawyer's Work Reports for Publicly Issued Securities" and other relevant laws, administrative regulations, rules, and normative documents effective within the territory of the People's Republic of China (hereinafter referred to as "China", for the purpose of this legal opinion, excluding the Hong Kong Special Administrative Region, Macao Special Administrative Region, and Taiwan Province).
In light of the Shenzhen Stock Exchange (hereinafter referred to as "SZSE") issuing the review letter [2026] 020039 on May 13, 2026, regarding the inquiry on Nanjing Sanchao New Materials Co., Ltd.'s application for the issuance of shares to specific investors (hereinafter referred to as "the Inquiry Letter"), our firm is now issuing this "Supplementary Legal Opinion on Nanjing Sanchao New Materials Co., Ltd.'s 2025 A-Share Issuance to Specific Investors (I)" (hereinafter referred to as "this Supplementary Legal Opinion") based on the relevant issues that the issuer's lawyer needs to explain as stated in the Inquiry Letter.
Our firm and the handling lawyers have strictly fulfilled their statutory duties in accordance with the Securities Law, the Securities Legal Business Management Measures, and the Securities Legal Business Practice Rules, and have conducted thorough verification to ensure that the facts recognized in this Supplementary Legal Opinion are true, accurate, and complete, and that the opinions expressed are legal and accurate, with no false records, misleading statements, or significant omissions, and bear corresponding legal responsibilities. This Supplementary Legal Opinion is a supplement and modification to the Lawyer's Work Report and the Legal Opinion and constitutes an inseparable part of the Lawyer's Work Report and the Legal Opinion. The premises and assumptions under which our firm expressed legal opinions in the Lawyer's Work Report and the Legal Opinion also apply to this Supplementary Legal Opinion. Unless otherwise specified, the terms and abbreviations used in this Supplementary Legal Opinion have the same meanings as those used in the Lawyer's Work Report and the Legal Opinion.