Shanghai Landing Law Firm
Legal Opinion on Huachen Precision (Kunshan) Co., Ltd.'s 2024 Restricted Stock Incentive Plan Adjustment of Grant Price and Cancellation of Part of Restricted Shares
To: Huachen Precision (Kunshan) Co., Ltd.
Shanghai Landing Law Firm has been entrusted by Huachen Precision (Kunshan) Co., Ltd. (hereinafter referred to as "Huachen Precision" or "the Company", stock code: 300809) to issue this legal opinion on matters related to the Company's implementation of the 2024 Restricted Stock Incentive Plan (hereinafter referred to as "the Incentive Plan").
Based on the "Company Law of the People's Republic of China," "Securities Law of the People's Republic of China," "Administrative Measures for Equity Incentives of Listed Companies," "Shenzhen Stock Exchange GEM Stock Listing Rules," and "Shenzhen Stock Exchange GEM Listed Company Self-Regulatory Management Guide No. 1—Business Handling," and other relevant laws, regulations, normative documents, and the "Articles of Association of Huachen Precision (Kunshan) Co., Ltd.," in accordance with the industry-recognized business standards, ethical norms, and the spirit of diligence and conscientiousness, the lawyers of this firm issued the "Legal Opinion on the Draft of Huachen Precision (Kunshan) Co., Ltd.'s 2024 Restricted Stock Incentive Plan" (hereinafter referred to as the "Draft Legal Opinion") on November 13, 2024, the "Legal Opinion on the First Grant of Restricted Shares of Huachen Precision (Kunshan) Co., Ltd.'s 2024 Restricted Stock Incentive Plan" on November 29, 2024, and the "Legal Opinion on the Grant of Reserved Restricted Shares of Huachen Precision (Kunshan) Co., Ltd.'s 2024 Restricted Stock Incentive Plan" on September 29, 2025. This legal opinion is issued after inspecting and verifying the relevant matters concerning the adjustment of the grant price and the cancellation of part of the restricted shares under the Incentive Plan.
To issue this legal opinion, the lawyers of this firm make the following statements:
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In accordance with the "Securities Law of the People's Republic of China," the "Administrative Measures for Securities Legal Business of Law Firms," and the "Practice Rules for Securities Legal Business of Law Firms (Trial)," and based on facts that have occurred or existed before the issuance date of this legal opinion, the lawyers of this firm have strictly performed their statutory duties, adhered to the principle of diligence and good faith, conducted thorough investigations and verifications, and ensured that the facts determined in this legal opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without any false records, misleading statements, or major omissions, and shall bear corresponding legal responsibilities.
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This legal opinion shall be used in conjunction with the "Draft Legal Opinion" and other legal opinions. Unless otherwise specified, the abbreviations used in this legal opinion shall have the same meaning as in the "Draft Legal Opinion." The premises, assumptions, and statements made by this firm in the "Draft Legal Opinion" also apply to this legal opinion.
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This firm agrees that Huachen Precision may use this legal opinion as one of the necessary legal documents for the implementation of the 2024 Restricted Stock Incentive Plan, and will submit it along with other application materials to the Shenzhen Stock Exchange for public disclosure, and is willing to bear corresponding legal responsibilities according to law.
Main Text
I. Approval and Authorization Regarding the Implementation of the "2024 Restricted Stock Incentive Plan" and the Adjustment of Grant Price and Cancellation of Part of Restricted Shares
- On November 7, 2024, the Second Meeting of the Third Remuneration and Assessment Committee of Huachen Precision was held, and the "Proposal on the Draft of Huachen Precision (Kunshan) Co., Ltd.'s 2024 Restricted Stock Incentive Plan and its Summary" and the "Proposal on the Management Measures for the Implementation and Assessment of Huachen Precision (Kunshan) Co., Ltd.'s 2024 Restricted Stock Incentive Plan" were deliberated and approved.