Anhui Tianhe Law Office
Supplementary Legal Opinion Letter on Anhui Zhongfu Yuanchuang Technology Group Co., Ltd. Issuing Shares to Specific Objects (Revised Draft) (Exempt Version)
Address: 16th Floor, East District, Wealth Plaza B, 278 Suixi Road, Hefei City, Anhui Province
Phone: (0551) 62642792
Fax: (0551) 62620450
Table of Contents
- Response to Inquiry Letter ........................................... 5
- Question 1 ............................................................. 5
- Question 2 ............................................................ 37
- Changes Since the Issuance of the Legal Opinion Letter .......... 50
- Approval and Authorization for This Issuance ........................ 50
- Substantive Conditions for This Issuance ................................ 51
- Independence of the Issuer ............................................... 51
- Major Shareholders and Actual Controllers of the Issuer ............ 52
- Issuer's Capital and Its Evolution ...................................... 53
- Business of the Issuer .................................................. 53
- Related Transactions and Industry Competition ........................ 54
- Major Assets of the Issuer .............................................. 55
- Major Debts of the Issuer ............................................... 57
- Rules of Procedure for Shareholders' Meetings, Board of Directors, and Supervisory Board of the Issuer .......... 59
- Taxation of the Issuer .................................................. 60
- Conclusion Opinion .................................................... 63
Supplementary Legal Opinion Letter
To: Anhui Zhongfu Yuanchuang Technology Group Co., Ltd.
According to the provisions of the Securities Law, Company Law, Registration Management Measures, and relevant laws, regulations, and normative documents, Zhongfu Technology has signed a "Special Legal Advisor Contract" with our office, entrusting our lawyers to participate in the issuance of shares to specific objects. Our lawyers have issued a "Legal Opinion Letter" and "Lawyer's Work Report" regarding this issuance. Given that the Shenzhen Stock Exchange issued an inquiry letter on April 22, 2026, regarding the application for the issuance of shares to specific objects, and that Zhongfu Technology disclosed its 2025 annual report on April 27, 2026, our lawyers have conducted a review and verification of the relevant matters and issued this supplementary legal opinion letter. Except for the supplements or modifications made in this supplementary legal opinion letter, the contents of the previously issued "Legal Opinion Letter" and "Lawyer's Work Report" remain valid. If our lawyers verify that the relevant situation of the issuer is the same as that disclosed in the "Legal Opinion Letter" and "Lawyer's Work Report," and there are no supplements or modifications to our verification opinions, this supplementary legal opinion letter will not elaborate further. Unless otherwise specified, the abbreviations used in this supplementary legal opinion letter have the same meanings as those in the "Legal Opinion Letter" and "Lawyer's Work Report."