Grandall Law Firm (Guangzhou) Regarding Guangdong Aofei Data Technology Co., Ltd.'s 2025 Annual General Meeting Legal Opinion
Guangdong Aofei Data Technology Co., Ltd.:
In accordance with the requirements of the "Rules of Procedure for Shareholders' Meetings of Listed Companies" issued by the China Securities Regulatory Commission (hereinafter referred to as the "Shareholders' Meeting Rules"), Grandall Law Firm (Guangzhou) (hereinafter referred to as the "Firm") was entrusted by Guangdong Aofei Data Technology Co., Ltd. (hereinafter referred to as "Aofei Data" or the "Company") to appoint Chen Wei and Chen Ying, lawyers (hereinafter referred to as "Firm Lawyers"), to attend Aofei Data's 2025 Annual General Meeting (hereinafter referred to as the "Meeting"). This legal opinion is issued on important matters such as the convening and holding procedures of the Meeting, the qualifications of attendees and the convener, and the voting procedures and results.
The Firm and its lawyers, in accordance with the "Company Law of the People's Republic of China" (hereinafter referred to as the "Company Law"), the "Administrative Measures for Law Firms Engaging in Securities Legal Business," and the "Practice Rules for Law Firms Engaging in Securities Legal Business (Trial)," and based on facts that have occurred or existed prior to the 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. The conclusions expressed are legal and accurate, and do not contain any false records, misleading statements, or significant omissions, and the Firm assumes corresponding legal responsibilities.
I. Convening and Holding of the Meeting
(I) Convening of the Meeting
The Meeting was convened by the Board of Directors of Aofei Data in accordance with the resolution of the 32nd meeting of the Fourth Board of Directors held on April 16, 2026. Aofei Data announced the "Notice of Guangdong Aofei Data Technology Co., Ltd. on Convening the 2025 Annual General Meeting" on the Juchao Information Network and other relevant websites on April 18, 2026. The notice disclosed the time and place of the Meeting, the matters to be considered, the qualifications of attendees, and registration matters within the statutory period.
The Firm Lawyers are of the opinion that the convening procedures of the Meeting comply with the "Company Law," the "Shareholders' Meeting Rules," the "Guiding Opinions on the Regulation of Listed Companies on the GEM of the Shenzhen Stock Exchange No. 2 - Norms for the Operation of GEM Listed Companies" (hereinafter referred to as the "GEM Listed Company Norms"), the "Implementation Rules for Network Voting of Shareholders' Meetings of Listed Companies of the Shenzhen Stock Exchange" (hereinafter referred to as the "Network Voting Implementation Rules"), and the Articles of Association of Aofei Data.
(II) Holding of the Meeting