King & Wood Mallesons (Jinan) Law Firm No. 33F, North Tower, China Life Building, 11001 Jingshi Road, Lixia District, Jinan, Shandong, 250014, PRC T +86 531 5583 1600 F +86 531 5583 1611 www.kingandwood.com
To: Shandong Dongyue Organosilicon Materials Co., Ltd.
King & Wood Mallesons (Jinan) Law Firm (hereinafter referred to as "the Firm") has been retained by Shandong Dongyue Organosilicon Materials Co., Ltd. (hereinafter referred to as "the Company") to, in accordance with the Securities Law of the People's Republic of China (hereinafter referred to as "Securities Law"), the Company Law of the People's Republic of China (hereinafter referred to as "Company Law"), the Rules of the Shareholders' Meeting of Listed Companies issued by the China Securities Regulatory Commission (hereinafter referred to as "Shareholders' Meeting Rules"), and other currently effective laws, administrative regulations, rules, and normative documents in the People's Republic of China (including the Hong Kong Special Administrative Region, the Macao Special Administrative Region, and Taiwan Province of China) (hereinafter referred to as "within Chinese territory," which, for the purpose of applying laws and regulations in this Legal Opinion, specifically refers to mainland China), and the Company's current effective articles of association, appoint lawyers to attend the 2025 Annual Shareholders' Meeting (hereinafter referred to as "the Meeting") held by the Company on April 16, 2026, and to issue this Legal Opinion on the Meeting.
To issue this Legal Opinion, the Firm's lawyers have reviewed the following documents provided by the Company, including but not limited to:
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The Articles of Association of Shandong Dongyue Organosilicon Materials Co., Ltd. (hereinafter referred to as "Articles of Association"), deliberated and approved by the Company's First Extraordinary Shareholders' Meeting in 2025;
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The Announcement of the Resolution of the 17th Meeting of the Third Board of Directors of Shandong Dongyue Organosilicon Materials Co., Ltd., disclosed by the Company on December 30, 2025, on the CNINFO website (http://www.cninfo.com.cn, hereinafter referred to as "CNINFO") and the Shenzhen Stock Exchange website (https://www.szse.cn/, hereinafter referred to as "SZSE website");
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The Announcement of the Resolution of the 18th Meeting of the Third Board of Directors of Shandong Dongyue Organosilicon Materials Co., Ltd., disclosed by the Company on March 26, 2026, on CNINFO and the SZSE website;
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The Notice of the 2025 Annual Shareholders' Meeting of Shandong Dongyue Organosilicon Materials Co., Ltd., disclosed by the Company on March 26, 2026, on CNINFO and the SZSE website (hereinafter referred to as "the Meeting Notice");
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The Company's shareholder register for the record date of the Meeting;
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Registration records and supporting documents of shareholders attending the on-site meeting;
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Statistical results of the online voting for the Meeting provided by Shenzhen Securities Information Co., Ltd.;
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The Company's proposals for the Meeting and announcements related to the proposals;
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Other meeting documents.
The Company has warranted to the Firm that it has disclosed all facts that may affect the issuance of this Legal Opinion and has provided the Firm with all original written materials, copies, photocopies, letters of commitment, or certifications requested by the Firm for the issuance of this Legal Opinion, without any concealment, false representation, or material omission. The documents and materials provided by the Company to the Firm are true, accurate, complete, and valid. Where they are copies or photocopies, they are consistent with the originals.
In this Legal Opinion, the Firm expresses opinions solely on the procedures for convening and holding the Meeting, the qualifications of attendees and the convener, and the voting procedures and results, as to whether they comply with relevant laws, administrative regulations, the "Shareholders' Meeting Rules," and the "Articles of Association." The Firm does not express opinions on the content of the proposals deliberated at the Meeting or the truthfulness and accuracy of the facts or data stated in these proposals. The Firm expresses opinions based solely on the currently effective laws and regulations within Chinese territory and not on any laws outside of China.