Kangda Law Firm
Legal Opinion
To: Yangzhou Haichang New Material 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 "Rules for Shareholders' Meetings of Listed Companies" (hereinafter referred to as the "Rules"), the Articles of Association of Yangzhou Haichang New Material Co., Ltd. (hereinafter referred to as the "Articles of Association"), and the legal advisory agreement signed between Yangzhou Haichang New Material Co., Ltd. (hereinafter referred to as the "Company") and Kangda Law Firm of Beijing (hereinafter referred to as the "Firm"), the Firm's lawyers have witnessed the Company's 2025 Annual General Meeting and hereby issue this Legal Opinion.
For the purpose of issuing this Legal Opinion, the Firm's lawyers make the following statements:
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The legal opinions expressed by the Firm's lawyers in this Legal Opinion are based on facts that occurred or existed on or before the date of issuance of this Legal Opinion and on the Firm's lawyers' understanding of relevant laws, regulations, and normative documents. In this Legal Opinion, the Firm's lawyers will only review and witness the procedures for convening and holding the meeting, the qualifications of the attendees, the voting procedures, and the voting results of this meeting and express legal opinions on these matters. The Firm's lawyers will not express opinions on the content of the proposals reviewed at this meeting or the truthfulness and accuracy of the facts and data involved in the proposals.
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The Firm's lawyers have expressed legal opinions on the truthfulness and legality of the Company's 2025 Annual General Meeting in accordance with the requirements of the "Company Law," the "Rules," and the "Articles of Association." This Legal Opinion does not contain any false, misleading statements or material omissions, otherwise, the Firm will bear corresponding legal responsibility.
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The Firm's lawyers agree that this Legal Opinion will be announced as a mandatory document for the Company's meeting and will bear legal responsibility for the legal opinions issued by the Firm in accordance with the law.
The Firm's lawyers have reviewed all documents and materials related to the issuance of this Legal Opinion, witnessed this meeting, and hereby issue the following legal opinion:
I. Convocation and Convening Procedures of the Meeting
(I) Convocation of the Meeting
The Firm's lawyers have inspected the meeting notice issued by the Company's Board of Directors. This shareholders' meeting was proposed and convened by the Company's Board of Directors. On March 24, 2026, the Company held the 23rd meeting of the third Board of Directors, which deliberated and approved the "Proposal on Convening the 2025 Annual General Meeting." On March 26, 2026, the Company published the "Notice of Yangzhou Haichang New Material Co., Ltd. on Convening the 2025 Annual General Meeting" (Announcement No.: 2026-012) on the information disclosure website designated by the China Securities Regulatory Commission, announcing the time, place, meeting agenda, and other related matters for this meeting.
Upon verification, the Company's Board of Directors notified all shareholders 20 days prior to the convening of this shareholders' meeting through an announcement.
According to the above announcement, the Company's Board of Directors specified the time, place, attendees, agenda items, and registration methods for this shareholders' meeting in the notice, and fully disclosed the content of all proposals in accordance with the relevant provisions of the "Company Law," the "Rules," and the "Articles of Association."
(II) Convening of the Meeting