Supplementary Legal Opinion (IV)
Guangdong Xinda Law Firm on Zhongshan United Optoelectronics Co., Ltd.'s Share Issuance for Asset Acquisition and Related Transactions
Address
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
Supplementary Legal Opinion (IV)
Guangdong Xinda Law Firm, in accordance with the special legal advisory service contract signed with Zhongshan United Optoelectronics Co., Ltd., has been entrusted to act as the special legal advisor for the issuance of shares for asset acquisition and related fundraising.
According to the relevant provisions of the Company Law of the People's Republic of China, the Securities Law of the People's Republic of China, the Administrative Measures for Major Asset Restructuring of Listed Companies, the Administrative Measures for Securities Issuance Registration of Listed Companies, the Regulatory Guidelines No. 9 for Listed Companies on Planning and Implementing Major Asset Restructuring, the Shenzhen Stock Exchange Listing Rules, and other relevant laws, regulations, and normative documents, the law firm has issued the following legal opinions:
- On December 1, 2025, the legal opinion on the share issuance for asset acquisition and related transactions.
- On December 18, 2025, the first supplementary legal opinion.
- On February 11, 2026, the second supplementary legal opinion.
- On March 25, 2026, the third supplementary legal opinion.
- On April 13, 2026, the revised second supplementary legal opinion.
The aforementioned legal opinions are collectively referred to as the "Original Legal Opinions."
Given that the audit benchmark date for this transaction has been updated to December 31, 2025, the audit firm has conducted an extended audit of the target company and issued the "Audit Report of Dongguan Changyi Optoelectronics Co., Ltd." and the "Review Report of Zhongshan United Optoelectronics Co., Ltd. for the 2025 Financial Statements."