Supplementary Legal Opinion (II)
To: Fujian Ashine Innovation Materials Co., Ltd.
Pursuant to the "Securities Legal Services Entrustment Contract" signed between Fujian Ashine Innovation Materials Co., Ltd. (hereinafter referred to as the "Issuer," "Company," "Listed Company," or "Ashine") and Grandall Law Firm (Fuzhou) (hereinafter referred to as "this Firm"), this Firm was engaged by the Issuer to appoint attorneys Li Tong, Guo Lizheng, Huang Sanyuan, and Chen Xiaoyue (hereinafter referred to as "our attorneys") to serve as special legal counsel for the Issuer's application for the 2025 issuance and listing of RMB ordinary shares (A shares) to specific targets (hereinafter referred to as "this Issuance and Listing"). This Firm previously issued the "Grandall Law Firm (Fuzhou) Legal Opinion on the 2025 Issuance and Listing of RMB Ordinary Shares (A Shares) to Specific Targets by Fujian Ashine Innovation Materials Co., Ltd." (hereinafter referred to as the "Legal Opinion") and the "Grandall Law Firm (Fuzhou) Attorney Work Report on the 2025 Issuance and Listing of RMB Ordinary Shares (A Shares) to Specific Targets by Fujian Ashine Innovation Materials Co., Ltd." (hereinafter referred to as the "Attorney Work Report") on April 12, 2026. Based on the 2025 audit report issued by Zhixin Certified Public Accountants and changes in legal matters related to this Issuance, we also issued the "Grandall Law Firm (Fuzhou) Supplementary Legal Opinion (I) on the 2025 Issuance and Listing of RMB Ordinary Shares (A Shares) to Specific Targets by Fujian Ashine Innovation Materials Co., Ltd." (hereinafter referred to as "Supplementary Legal Opinion (I)").
On May 6, 2026, the Shenzhen Stock Exchange issued the "Audit Inquiry Letter Regarding the Application of Fujian Ashine Innovation Materials Co., Ltd. for Issuance of Shares to Specific Targets" (Audit Letter [2026] No. 020035, hereinafter referred to as the "Audit Inquiry Letter"). In accordance with the relevant regulations and requirements of the China Securities Regulatory Commission (hereinafter referred to as the "CSRC") and the Shenzhen Stock Exchange, our attorneys have verified and responded to the relevant issues involved in the Audit Inquiry Letter, and hereby issue this "Grandall Law Firm (Fuzhou) Supplementary Legal Opinion (II) on the 2025 Issuance and Listing of RMB Ordinary Shares (A Shares) to Specific Targets by Fujian Ashine Innovation Materials Co., Ltd." (hereinafter referred to as this Supplementary Legal Opinion).
This Supplementary Legal Opinion serves as a supplement to the "Legal Opinion," "Attorney Work Report," and "Supplementary Legal Opinion (I)." In case of any inconsistency, this Supplementary Legal Opinion shall prevail. For matters not covered herein, the "Legal Opinion," "Attorney Work Report," and "Supplementary Legal Opinion (I)" shall prevail.
Unless otherwise specified in the context, the abbreviations, terms, and definitions used in this Supplementary Legal Opinion have the same meanings as those used in the "Legal Opinion," "Attorney Work Report," and "Supplementary Legal Opinion (I)." The statements and assumptions made by this Firm in the "Legal Opinion" and "Attorney Work Report" apply to this Supplementary Legal Opinion.
In accordance with the "Company Law of the People's Republic of China," the "Securities Law of the People's Republic of China," and other relevant laws and regulations, and following the business standards, ethical norms, and the spirit of diligence and responsibility recognized in the legal profession, our attorneys hereby issue this Supplementary Legal Opinion regarding this Issuance and Listing as follows:
Section 1 Main Text
Audit Inquiry Letter Question 1-(3)