Legal Opinion
Sundial Law Firm SUNDIAL LAW FIRM
China Shenzhen Futian District Yitian Road 6001 Taiping Finance Tower 11th, 12th Floor Postal Code: 518038 11F/12F., Taiping Finance Tower, 6001 Yitian Road, Futian District, Shenzhen, P.R. China 518038 Tel.: (0755) 8826 5288 Fax: (0755) 8826 5537 Website: www.sundiallawfirm.com
Guangdong Sundial Law Firm Regarding the 2025 Annual General Meeting of Zhongshan Broad-Ocean Technology Co., Ltd. Legal Opinion Dacheng Hui Zi (2026) No. 102
To: Zhongshan Broad-Ocean Technology Co., Ltd.
Guangdong Sundial Law Firm (hereinafter referred to as "Sundial") was entrusted by Zhongshan Broad-Ocean Technology Co., Ltd. (hereinafter referred to as the "Company") to appoint Sundial lawyers to attend the 2025 Annual General Meeting of the Company (hereinafter referred to as the "Meeting") and to witness the legality of the Meeting.
Sundial lawyers, 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 "Shareholders' Meeting Rules"), and other laws, regulations, and normative legal documents, as well as the provisions of the "Articles of Association of Zhongshan Broad-Ocean Technology Co., Ltd." (hereinafter referred to as the "Articles of Association"), hereby issue this Legal Opinion on matters such as the convening and procedures of the Meeting, the qualifications of the attendees, the qualifications of the convener, the voting procedures, and the voting results.
Regarding the issuance of this Legal Opinion, Sundial lawyers hereby make the following statements:
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Sundial lawyers will only express opinions on the legality of the convening and procedures of the Meeting, the qualifications of the convener and attendees, the voting procedures, and the voting results. They will not express opinions on the authenticity, accuracy, and completeness of the facts or data stated in the proposals deliberated at the Meeting;
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Sundial lawyers are unable to witness the online voting process. The qualifications of shareholders participating in the online voting and the online voting results are certified by the securities exchange trading system and the internet voting system;
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Sundial and Sundial lawyers, in accordance with the "Securities Law of the People's Republic of China," the "Measures for the Administration of Securities Legal Business of Law Firms," and the "Practice Rules for Securities Legal Business of Law Firms (Trial)," and based on facts that have already occurred or exist as of the date of issuance of this Legal Opinion, have strictly performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough investigations and verifications, and ensured that the facts identified in this Legal Opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without any false records, misleading statements, or material omissions, and shall bear corresponding legal responsibilities;
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This Legal Opinion is for the purpose of verifying the legality of the matters related to the Company's Meeting only and shall not be used for any other purpose. Sundial lawyers agree to attach this Legal Opinion to the resolution of the Company's Meeting for public announcement and shall bear corresponding responsibilities according to law.
Sundial lawyers, in accordance with the "Company Law," the "Securities Law of the People's Republic of China," the "Shareholders' Meeting Rules," the "Measures for the Administration of Securities Legal Business of Law Firms," the "Practice Rules for Securities Legal Business of Law Firms (Trial)," and the "Articles of Association," and in accordance with the generally accepted business standards, ethical norms, and the spirit of diligence in the legal profession, have investigated and verified the relevant materials and facts of the Meeting and hereby express the following legal opinions: