Legal Opinion on Shareholder Change and Controlling Shareholder/Actual Controller Change of Sunsea Technology Group Co., Ltd.
To: Beijing Junhe Law Firm
From: Beijing Junhe Law Firm
Subject: Legal Opinion on Shareholder Change and Controlling Shareholder/Actual Controller Change of Sunsea Technology Group Co., Ltd.
Date: July 2026
I. Termination of Acting-in-Concert Relationship
A. Termination of Acting-in-Concert Relationship
On April 2, 2013, Wuxi Puhua, Wuxi Qunying, Wuxi Jiehua, Wuxi Daoyuan, and Wuxi Ruifeng signed an "Acting-in-Concert Agreement." On March 1, 2019, Wuxi Puhua, Wuxi Qunying, Wuxi Jiehua, Wuxi Daoyuan, Wuxi Ruifeng, Wuxi Bopai, and Wuxi Xinxin signed an "Acting-in-Concert Agreement."
According to the information provided by the Company, the parties to the above acting-in-concert agreements have signed "Acting-in-Concert Termination Agreements" to terminate the acting-in-concert relationships.
Based on the information provided by the Company, the Company has provided all original materials, supplementary materials, and copies of materials required for this legal opinion. The materials provided are true, accurate, complete, and valid, and there are no omissions or false statements.
The law firm has reviewed the materials provided by the Company and believes that the termination of the acting-in-concert relationship is consistent with the relevant provisions of Chinese laws and regulations. The law firm has also reviewed the relevant laws and regulations and the factual circumstances that have occurred or existed prior to the issuance of this legal opinion.
The law firm has reviewed the "Securities Law," "Lawyer's Law," and "Administrative Regulations on the Supervision and Administration of the Securities Market," and other relevant laws and regulations, and has conducted necessary checks on the facts.