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Beijing Zhong Lun Law Firm
Supplementary Legal Opinion on the Issuance of Shares to Specific Targets by Guangdong Jinma Amusement Rides Co., Ltd.
August 2026
Table of Contents
Table of Contents 1
I. Inquiry Letter Question 1 3
II. Inquiry Letter Question 2 10
III. Inquiry Letter Question 3 26
IV. Supplementary Update Items 26
Appendix: Issuer's Patents 32
To: Guangdong Jinma Amusement Rides Co., Ltd.
Beijing Zhong Lun Law Firm (hereinafter referred to as "this Firm") was engaged by Guangdong Jinma Amusement Rides Co., Ltd. (hereinafter referred to as the "Issuer," "Jinma Amusement," or the "Company") to serve as special legal counsel for the Issuer's issuance of shares to specific targets (hereinafter referred to as the "Issuance").
On May 12, 2026, this Firm issued the "Legal Opinion of Beijing Zhong Lun Law Firm on the Issuance of Shares to Specific Targets by Guangdong Jinma Amusement Rides Co., Ltd." (hereinafter referred to as the "Original Legal Opinion") and the "Attorney's Work Report of Beijing Zhong Lun Law Firm on the Issuance of Shares to Specific Targets by Guangdong Jinma Amusement Rides Co., Ltd." (hereinafter referred to as the "Attorney's Work Report").
In view of the "Audit Inquiry Letter on the Application of Guangdong Jinma Amusement Rides Co., Ltd. for Issuance of Shares to Specific Targets" (Audit Letter [2026] No. 020049, hereinafter referred to as the "Inquiry Letter") issued by the Shenzhen Stock Exchange, this Firm hereby issues this "Supplementary Legal Opinion of Beijing Zhong Lun Law Firm on the Issuance of Shares to Specific Targets by Guangdong Jinma Amusement Rides Co., Ltd." (hereinafter referred to as this "Supplementary Legal Opinion") regarding the matters involved in the Inquiry Letter.
Unless otherwise specified, the terms, names, and abbreviations used in this Supplementary Legal Opinion have the same meanings as those in the Original Legal Opinion and the Attorney's Work Report.
Unless otherwise specified, the matters declared by the lawyers of this Firm in the Original Legal Opinion and the Attorney's Work Report apply to this Supplementary Legal Opinion.
To issue this Supplementary Legal Opinion, the lawyers of this Firm have checked and verified the relevant issues involved in this Supplementary Legal Opinion in accordance with the provisions of relevant laws, administrative regulations, and normative documents, as well as the requirements of this Firm's business rules, in line with the principles of prudence and materiality.
This Firm and the handling lawyers have strictly fulfilled their statutory duties, followed the principles of diligence, due diligence, and good faith, and conducted sufficient verification based on the "Securities Law," the "Administrative Measures for Securities Legal Business of Law Firms," and the "Practice Rules for Securities Legal Business of Law Firms (Trial)," as well as facts that occurred or existed before the issuance date of this Supplementary Legal Opinion. We ensure that the facts recognized in this Supplementary Legal Opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without false records, misleading statements, or major omissions, and we are willing to bear the corresponding legal liabilities.
In accordance with Article 19 of the "Securities Law" and following the recognized business standards, ethical norms, and the spirit of diligence and due diligence of the legal profession, this Firm's lawyers hereby issue this supplementary legal opinion based on the verification of the documents, materials, and facts related to the Issuer's Issuance (all the above contents are subject to and limited to the matters on which this Supplementary Legal Opinion expresses an opinion):