Beijing Dachen Law Firm
Legal Opinion on the Achievement of Conditions for the Second Exercise Period and the Cancellation of Part of the Stock Options under the 2023 Stock Option Incentive Plan of Beijing Compass Technology Development Co., Ltd.
Dacheng Certificate of Securities [2026] No. 064
To: Beijing Compass Technology Development Co., Ltd.
Beijing Dachen Law Firm, commissioned by Beijing Compass Technology Development Co., Ltd., hereby issues this legal opinion as special legal counsel for the company's 2023 Stock Option Incentive Plan regarding the achievement of conditions for the second exercise period and the cancellation of part of the stock options.
Our lawyers, in accordance with the "Company Law," "Securities Law," "Management Measures," "Measures for the Administration of Securities Law Practice by Law Firms," "Guiding Principles No. 1 for Self-Regulation of the Shenzhen Stock Exchange," and other relevant laws, regulations, and normative documents, as well as the "Articles of Association" and the "Incentive Plan," have conducted verification work based on facts and in accordance with the principles of law, adhering to the recognized professional standards, ethical norms, and diligence of the legal profession, and have issued the "Legal Opinion of Beijing Dachen Law Firm on the Achievement of Conditions for the Second Exercise Period and the Cancellation of Part of the Stock Options under the 2023 Stock Option Incentive Plan of Beijing Compass Technology Development Co., Ltd."
Our lawyers undertake that they have fully investigated and verified the legality and compliance of the company's actions and the matters concerning the achievement of conditions for the second exercise period and the cancellation of part of the stock options under the 2023 Stock Option Incentive Plan, and guarantee the truthfulness, accuracy, and completeness of this legal opinion.
Section 1 Lawyer's Statement
In order to issue this legal opinion, our lawyers make the following statements:
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Our firm and the handling lawyers, in accordance with the provisions of the "Company Law," "Securities Law," "Management Measures," "Guiding Principles No. 1 for Self-Regulation," and other relevant laws, regulations, and normative documents, and based on facts that have occurred or existed prior to the issuance date of this legal opinion, have strictly performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough verification, and ensured that the facts identified in the legal opinion are true, accurate, and complete. The conclusions expressed are legal and accurate, and do not contain any false records, misleading statements, or material omissions, and we bear corresponding legal responsibilities.
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This legal opinion is issued based on the currently effective laws of the People's Republic of China or the company's actions, relevant facts that have occurred or existed at the time, and the applicable laws, administrative regulations, rules, and normative documents, and based on our lawyers' understanding of these provisions.
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Our lawyers agree that this legal opinion will be used as an essential legal document for the company in implementing the incentive plan, and will be submitted together with other materials or publicly disclosed, and we are willing to bear the corresponding legal responsibilities.
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The company guarantees that it has provided our lawyers with all the original written materials, duplicate materials, or oral statements necessary for the issuance of this legal opinion, which are true and complete.
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For facts that are crucial to this legal opinion but cannot be independently supported by evidence, our lawyers rely on supporting documents, certificates, or copies of documents provided by relevant government departments, the company, or other relevant entities or individuals to issue this legal opinion.