Tianhe Law Firm
Special Audit Opinion
Anhui Tianhe Law Firm
Special Audit Opinion on the Situation of Insiders Trading Stocks During the Self-Inspection Period of Tianjin Ruisin Technology Co., Ltd.'s Issuance of Shares and Payment of Cash to Purchase Assets and Raising Supporting Funds for Connected Transactions
Tianjin He 2026 No. 01694
To: Tianjin Ruisin Technology Co., Ltd.
Pursuant to the "Company Law of the People's Republic of China" (hereinafter referred to as the "Company Law"), the "Securities Law of the People's Republic of China" (hereinafter referred to as the "Securities Law"), the "Measures for the Administration of Major Asset Restructuring of Listed Companies" (hereinafter referred to as the "Restructuring Measures") and other relevant laws, regulations, and normative documents, Anhui Tianhe Law Firm (hereinafter referred to as the "Firm") has been entrusted by Tianjin Ruisin Technology Co., Ltd. (hereinafter referred to as "Ruisin Technology" or the "Company") to serve as its special legal advisor for this transaction and has issued the "Legal Opinion of Anhui Tianhe Law Firm on Tianjin Ruisin Technology Co., Ltd.'s Issuance of Shares and Payment of Cash to Purchase Assets and Raising Supporting Funds for Connected Transactions" (hereinafter referred to as the "Legal Opinion").
In accordance with the requirements of the "Format Rules for Information Disclosure by Companies Issuing Securities No. 26 – Major Asset Restructuring of Listed Companies," the "Supervision and Administration Guide – Class I Listed Companies," and the "Shenzhen Stock Exchange Listed Company Self-Regulation Guidelines No. 8 – Major Asset Restructuring," and other laws, regulations, and normative documents, the Firm's lawyers have conducted a special audit and verification of the stock trading situation of insiders involved in this transaction during the self-inspection period and have issued this Special Audit Opinion (hereinafter referred to as the "Special Audit Opinion").
The statements made by the Firm's lawyers in the "Legal Opinion" continue to apply to this Special Audit Opinion. Unless otherwise specified, the abbreviations and terms used in this Special Audit Opinion have the same meanings as those in the "Legal Opinion."
The Firm's lawyers agree that this Special Audit Opinion can be used as a necessary legal document for this transaction, to be submitted along with other application materials for information disclosure, and they shall be legally responsible for the legal opinions expressed herein. This Special Audit Opinion is for the sole use of the Company for this transaction and shall not be used for any other purpose.
In accordance with the requirements of relevant laws and regulations, and adhering to the generally accepted business standards, ethical norms, and the spirit of diligence and conscientiousness of the legal profession, the Firm's lawyers hereby issue the Special Audit Opinion as follows:
I. Self-Inspection of Stock Trading by Insiders in the Major Asset Restructuring
(I) Self-Inspection Period for Stock Trading by Insiders in the Major Asset Restructuring
According to the "Supervision and Administration Guide – Class I Listed Companies," the self-inspection period for stock trading by insiders in this transaction is the six months prior to the date Ruisin Technology applied for stock suspension for this major asset restructuring (February 4, 2026) up to the date the "Restructuring Report" was disclosed (June 8, 2026), i.e., from August 4, 2025, to June 8, 2026 (hereinafter referred to as the "Self-Inspection Period").
(II) Scope of Self-Inspection for Insiders in the Major Asset Restructuring
The scope of self-inspection for insiders in this major asset restructuring includes: