This legal opinion is issued by Zhong Lun Law Firm (hereinafter referred to as "the Firm") at the request of Qingdao Huicheng Environmental Protection Technology Group Co., Ltd. (hereinafter referred to as "the Company") regarding the matters concerning the convening of the Company's 2025 Annual Shareholders' Meeting (hereinafter referred to as "the Shareholders' Meeting"). In accordance with the "Company Law of the People's Republic of China" (hereinafter referred to as "Company Law"), the "Securities Law of the People's Republic of China" (hereinafter referred to as "Securities Law"), the "Rules for Shareholders' Meetings of Listed Companies" issued by the China Securities Regulatory Commission (hereinafter referred to as "Shareholders' Meeting Rules"), the "Administrative Measures for Law Firms Engaging in Securities Legal Business" (hereinafter referred to as "Business Measures"), and other relevant laws, regulations, and rules, as well as the "Articles of Association of Qingdao Huicheng Environmental Protection Technology Group Co., Ltd." (hereinafter referred to as "Articles of Association"), the Firm hereby issues this legal opinion.
The Firm's lawyers have conducted investigations and verifications in accordance with the requirements of the "Business Measures" regarding the authenticity and legality of the Shareholders' Meeting and have expressed their legal opinions. To issue this legal opinion, the Firm's lawyers have reviewed the relevant documents and materials of the Shareholders' Meeting. The Firm's lawyers have received the Company's assurance that it has provided all materials deemed necessary by the Firm's lawyers for issuing this legal opinion, and that the original materials, copies, and other materials provided, as well as oral statements, are true, accurate, and complete. The copies and other materials are consistent with the original materials. The Firm's lawyers agree to include this legal opinion in the Company's other information disclosure materials for the Shareholders' Meeting and will bear corresponding legal responsibilities according to law. This legal opinion is for the purpose of the Company's Shareholders' Meeting only and shall not be used for any other purpose.
The Firm and the handling lawyers have fulfilled their statutory duties and adhered to the principles of diligence and good faith in accordance with the provisions of the "Securities Law," "Administrative Measures for Law Firms Engaging in Securities Legal Business," and "Practice Rules for Law Firms Engaging in Securities Legal Business (Trial)," and based on the facts that have occurred or existed prior to the issuance date of this legal opinion, have conducted thorough investigations and verifications, ensuring that the facts identified in this legal opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without any false statements, misleading representations, or material omissions, and will bear corresponding legal responsibilities.
The Firm's lawyers hereby express their legal opinions on the facts related to the Shareholders' Meeting that occurred on or before the date of issuance of this legal opinion as follows:
I. Convening and Holding of the Shareholders' Meeting
(I) Convening of the Shareholders' Meeting
According to the "Announcement on the Resolution of the Fourth Meeting of the Fourth Board of Directors of Qingdao Huicheng Environmental Protection Technology Group Co., Ltd." and the "Notice of Qingdao Huicheng Environmental Protection Technology Group Co., Ltd. on Convening the 2025 Annual Shareholders' Meeting" (hereinafter referred to as the "Meeting Notice") published by the Company on Juchao Information Network (http://www.cninfo.com.cn) on April 21, 2026, the Shareholders' Meeting was convened by the Company's Board of Directors, and the Board of Directors has made a resolution to this effect.
Therefore, the Firm's lawyers are of the opinion that the convening of the Shareholders' Meeting complies with the relevant provisions of the "Company Law," "Securities Law," "Shareholders' Meeting Rules," and other laws, regulations, and the "Articles of Association."