King & Wood Mallesons Supplementary Legal Opinion on Beijing Capital Online Science & Technology Co., Ltd.'s Issuance of Shares to Specific Targets on the ChiNext Market
To: Beijing Capital Online Science & Technology Co., Ltd.
In accordance with the Securities Law of the People's Republic of China, the Company Law of the People's Republic of China, the Administrative Measures for the Registration of Securities Issuance by Listed Companies, the Administrative Measures for Law Firms Engaging in Securities Legal Business, the Practice Rules for Law Firms Engaging in Securities Legal Business (Trial), and the Notice of the China Securities Regulatory Commission on Issuing the "Compilation Rules for Information Disclosure by Companies Offering Securities to the Public No. 12 — Legal Opinions and Lawyer's Work Reports for Public Offering of Securities" (Zheng Jian Fa [2001] No. 37), and other currently effective laws, administrative regulations, departmental rules, and normative documents of the People's Republic of China (including the Hong Kong Special Administrative Region, the Macau Special Administrative Region, and Taiwan Province; hereinafter referred to as "Domestic China," which for the purpose of this supplementary legal opinion refers specifically to Mainland China), King & Wood Mallesons (hereinafter referred to as "the Firm" or "KWM") was engaged by Beijing Capital Online Science & Technology Co., Ltd. (hereinafter referred to as "the Issuer" or "Capital Online") to serve as the special legal counsel for the Issuer's issuance of A-shares to specific targets in Domestic China (hereinafter referred to as "this Issuance") and its listing on the ChiNext market of the Shenzhen Stock Exchange (hereinafter referred to as "the SZSE"). The Firm previously issued the "King & Wood Mallesons' Legal Opinion on Beijing Capital Online Science & Technology Co., Ltd.'s Issuance of Shares to Specific Targets on the ChiNext Market" (hereinafter referred to as "the Legal Opinion") and the "King & Wood Mallesons' Lawyer's Work Report on Beijing Capital Online Science & Technology Co., Ltd.'s Issuance of Shares to Specific Targets on the ChiNext Market" (hereinafter referred to as "the Lawyer's Work Report") on April 30, 2026.
The Firm has now conducted a verification of matters related to the Issuer's issuance in accordance with the requirements of the "Audit Inquiry Letter regarding Beijing Capital Online Science & Technology Co., Ltd.'s Application for Issuance of Shares to Specific Targets" (Audit Letter [2026] No. 020048, hereinafter referred to as "the Audit Inquiry Letter") issued by the SZSE Listing Audit Center on May 26, 2026, and hereby issues this supplementary legal opinion.
The premises and assumptions upon which KWM expressed its legal opinions in the Legal Opinion and the Lawyer's Work Report apply equally to this supplementary legal opinion. The definitions used in this supplementary legal opinion are the same as those in the Legal Opinion and the Lawyer's Work Report.
This supplementary legal opinion is intended solely for the Issuer's use in connection with this Issuance and may not be used for any other purpose.
KWM consents to this supplementary legal opinion being filed as a required statutory document for the Issuer's application for this Issuance, along with other application materials, and assumes corresponding legal responsibility.
In accordance with the professional standards, ethical norms, and the spirit of diligence and responsibility recognized in the legal profession, KWM has conducted further verification of the matters concerning the Issuer's counsel as involved in the Audit Inquiry Letter, supplemented the working papers, and now provides the following supplementary explanations and opinions (the following questions are excerpted from the Audit Inquiry Letter):
I. Question 1 of the Audit Inquiry Letter