Beijing Merits & Tree Law Offices
Regarding Shanghai Hanxun Information Technology Co., Ltd.'s Application for Issuance of Shares to Specific Objects
Supplementary Legal Opinion (I)
Zhide (Zheng) Zi [2026] No. 0002-6
To: Shanghai Hanxun Information Technology Co., Ltd. (Issuer)
Pursuant to the "Lawyer Service Agreement" signed between our firm and the Issuer, our firm has been appointed by the Issuer as its special legal counsel for this issuance.
In accordance with the "Company Law," "Securities Law," "Administrative Measures for Securities Legal Business," "Practice Rules for Securities Legal Business," and other laws, regulations, rules, normative documents, and relevant regulations of the China Securities Regulatory Commission and stock exchanges, and in accordance with the industry-recognized business standards, ethical norms, and diligent and conscientious spirit, our firm's lawyers have inspected the documents and facts related to the Issuer and this issuance, and have issued the "Beijing Merits & Tree Law Offices' Legal Opinion on Shanghai Hanxun Information Technology Co., Ltd.'s Application for Issuance of Shares to Specific Objects" (hereinafter referred to as the "Legal Opinion") and the "Beijing Merits & Tree Law Offices' Lawyer's Work Report on Shanghai Hanxun Information Technology Co., Ltd.'s Application for Issuance of Shares to Specific Objects" (hereinafter referred to as the "Work Report").
In response to the "Review Inquiry Letter Regarding Shanghai Hanxun Information Technology Co., Ltd.'s Application for Issuance of Shares to Specific Objects" (Review Letter [2026] No. 020010, hereinafter referred to as the "Inquiry Letter") and the Issuer's request, our firm's lawyers, based on further inspection of the Issuer's situation related to this issuance, hereby issue this Supplementary Legal Opinion to amend, supplement, or further explain the relevant content of the "Legal Opinion" and "Work Report" previously issued by our firm.
Our firm's lawyers agree to submit this Supplementary Legal Opinion as a necessary legal document for the Issuer's current issuance along with other materials, and shall bear corresponding legal responsibilities for this Supplementary Legal Opinion; this Supplementary Legal Opinion is only for the purpose of the Issuer's current issuance and shall not be used for any other purpose.
The statements made by our firm's lawyers in the "Legal Opinion" and "Work Report" also apply to this Supplementary Legal Opinion. Unless otherwise specified, the meanings of the terms in this Supplementary Legal Opinion are consistent with the meanings of the same terms in the "Legal Opinion" and "Work Report."
Our firm's lawyers, in accordance with the "Company Law," "Securities Law," "Administrative Measures for Securities Issuance and Registration," "Administrative Measures for Securities Legal Business," "Practice Rules for Securities Legal Business," and other relevant laws, regulations, rules, and normative documents, and in accordance with the industry-recognized business standards, ethical norms, and diligent and conscientious spirit, hereby issue the supplementary legal opinion as follows:
I. "Inquiry Letter" Question 3
In November 2025, the Issuer disclosed the "Notice of Change in Equity of Shanghai Hanxun Information Technology Co., Ltd. Regarding Proposed Transfer of Part of the Company's Shares by Controlling Shareholder via Agreement." The Issuer's controlling shareholder, Shanghai Shuangyou Information Technology Co., Ltd. (hereinafter referred to as Shanghai Shuangyou), proposed to transfer 31,398,289 shares held by it through an agreement transfer, representing 5.00% of the Issuer's total share capital. As of December 29, 2025, the Issuer announced that Shanghai Shuangyou had completed the registration of the transfer, and its shareholding increased to 80,125,604 shares, representing 12.76% of the total share capital. According to the declaration materials, one of the reasons for the controlling shareholder's reduction in holdings was to repay the debt from share pledge financing.