King & Wood Mallesons
Supplementary Legal Opinion on Beijing Capital Online Co., Ltd.'s Issuance of Shares to Specific Targets on the ChiNext Market
To: Beijing Capital Online 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 Registration of Securities Issuance by Listed Companies, the Administrative Measures for Securities Legal Business of Law Firms, the Practice Rules for Securities Legal Business of Law Firms (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 Opinion and Lawyer's Work Report 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 the Taiwan region; 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 "we" or "King & Wood") was engaged by Beijing Capital Online Co., Ltd. (hereinafter referred to as the "Issuer" or "Capital Online") as the special legal counsel for the Issuer's issuance of A-shares to specific targets in Domestic China (hereinafter referred to as the "Issuance") and its listing on the ChiNext market of the Shenzhen Stock Exchange (hereinafter referred to as the "SZSE"). We previously issued the "King & Wood Mallesons Legal Opinion on Beijing Capital Online 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 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.
In accordance with the requirements of the "Audit Inquiry Letter on Beijing Capital Online 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, we have conducted an inspection of matters related to the Issuer's Issuance and hereby issue this supplementary legal opinion.
The premises and assumptions upon which King & Wood 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 the Issuance and may not be used for any other purpose.
King & Wood consents to this supplementary legal opinion being used as a required statutory document for the Issuer's Issuance application, to be submitted along with other application materials, and assumes corresponding legal liability.
In accordance with the business standards, ethical norms, and the spirit of diligence and responsibility generally accepted in the legal profession, King & Wood has conducted further inspections of the matters involving the Issuer's counsel as requested by the "Audit Inquiry Letter," supplemented the working papers, and hereby 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"
According to the application materials, the company's main business revenue includes IDC service revenue, cloud host and related service revenue, and other revenue. During the reporting period, the company achieved operating revenue of 1,243.2873 million yuan, 1,396.7894 million yuan, and 1,236.5891 million yuan, respectively. The sales proportion of IDC services continued to decline, while the sales proportion of cloud host and related services continued to rise. The net profit attributable to shareholders of the listed company for each period was -340.079 million yuan, -303.144 million yuan, and -170.035 million yuan, respectively, representing continuous losses.