Guangdong Huashang Law Firm
Supplementary Legal Opinion (I)
Guangdong Huashang Law Firm Regarding Shenzhen Mind Electronic Technology Co., Ltd.'s Issuance of Shares to Specific Objects Supplementary Legal Opinion (I)
To: Shenzhen Mind Electronic Technology Co., Ltd.
Guangdong Huashang Law Firm (hereinafter referred to as the "Firm") has been appointed as the special legal advisor for Mind Electronic's issuance of shares to specific objects and provides specialized legal services for this issuance. After inspecting the relevant documents and facts provided by Mind Electronic to the Firm for this issuance, in accordance with the "Company Law," "Securities Law," "Administrative Measures for the Registration of Securities Issuances," and other relevant laws, regulations, and normative documents, and in accordance with the generally accepted professional standards, ethical norms, and diligence and conscientiousness of the legal profession, the Firm issued the "Lawyer's Work Report of Guangdong Huashang Law Firm on Shenzhen Mind Electronic Technology Co., Ltd.'s Issuance of Shares to Specific Objects" (hereinafter referred to as the "Work Report") and the "Legal Opinion of Guangdong Huashang Law Firm on Shenzhen Mind Electronic Technology Co., Ltd.'s Issuance of Shares to Specific Objects" (hereinafter referred to as the "Legal Opinion") on June 24, 2026.
Based on the "Inquiry Letter Regarding Shenzhen Mind Electronic Technology Co., Ltd.'s Application for Issuance of Shares to Specific Objects" issued by the Listing Review Center of the Shenzhen Stock Exchange on July 16, 2026 (hereinafter referred to as the "Inquiry Letter"), the Firm's lawyers hereby respond to the matters that require legal verification in the "Inquiry Letter" and issue the "Supplementary Legal Opinion (I) of Guangdong Huashang Law Firm on Shenzhen Mind Electronic Technology Co., Ltd.'s Issuance of Shares to Specific Objects" (hereinafter referred to as "Supplementary Legal Opinion (I)" or "this Supplementary Legal Opinion").
The Firm's lawyers have strictly performed their statutory duties, adhered to the principles of diligence and conscientiousness and good faith, and have conducted thorough investigations and verifications of the relevant issues involved in this Supplementary Legal Opinion, ensuring that this Supplementary Legal Opinion does not contain any false statements, misleading representations, or material omissions. This Supplementary Legal Opinion shall be used in conjunction with the "Legal Opinion" and the "Work Report." Unless otherwise specified, the definitions and abbreviations used in the "Legal Opinion" and the "Work Report" remain valid for this Supplementary Legal Opinion.
Based on the foregoing, the Firm's lawyers, in accordance with the generally accepted professional standards, ethical norms, and diligence and conscientiousness of the legal profession, hereby issue this Supplementary Legal Opinion.
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Main Text
"Inquiry Letter" Question 1
The total amount of capital to be raised in this issuance shall not exceed RMB 1 billion (inclusive), after deducting issuance expenses. The raised funds will be invested in the "Specialized High-Voltage Power Semiconductor Devices and Integrated Circuit Wafer Foundry Project" (hereinafter referred to as "Project 1"), supplementary working capital, and repayment of bank loans.
The implementing entity for the proposed investment projects is Zhejiang Guancheng Microelectronics Co., Ltd. (hereinafter referred to as "Guancheng Microelectronics"), a controlling subsidiary of the issuer. As of the reporting date, the issuer held a 50.10% stake in Guancheng Microelectronics. On May 9, 2026, and June 26, 2026, the issuer twice disclosed the "Announcement on Capital Increase of a Subsidiary and Waiver of Preemptive Rights," stating that Guancheng Microelectronics planned to introduce investors such as Huaxi Yinpeng Investment Co., Ltd. through capital increase and share expansion. After the capital increase, the issuer's equity ratio in Guancheng Microelectronics will decrease to 42.3380%. The proposed investment projects will be funded by the issuer providing loans to Guancheng Microelectronics, with minority shareholders not providing proportional loans.