DeHeng Law Offices
Legal Opinion on PuniTesting Group Co., Ltd.'s 2025 Annual General Meeting
Deheng 01G20200488-27
To: PuniTesting Group Co., Ltd.
DeHeng Law Offices was entrusted by PuniTesting Group Co., Ltd. (hereinafter referred to as the "Company") to appoint lawyers Peng Hong and Qiu Ru (hereinafter referred to as "our lawyers") to attend the 2025 Annual General Meeting of the Company (hereinafter referred to as the "Meeting") to witness the legality of the Meeting and issue this legal opinion.
This legal opinion is issued in accordance with 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 "Meeting Rules"), and other effective laws, regulations, and normative documents, as well as the "Articles of Association of PuniTesting Group Co., Ltd." (hereinafter referred to as the "Articles of Association").
To issue this legal opinion, our lawyers have reviewed the relevant documents and materials of the Meeting, and our lawyers attended the Meeting, participated in the verification of the identity documents of the on-site attendees, and witnessed the entire process of the Meeting's convening, voting, and resolution formation.
In this legal opinion, our lawyers only express opinions on whether the convening and holding procedures, attendee qualifications, convener qualifications, voting procedures, and voting results of the Meeting comply with the provisions of the "Company Law," "Meeting Rules," and other laws, regulations, normative documents, and the "Articles of Association." Opinions are not expressed on the truthfulness and accuracy of the facts or data stated in the proposals reviewed by the Meeting.
Our firm and the handling lawyers have fulfilled their statutory duties in accordance with the "Securities Law," the "Administrative Measures for Securities Law Business of Law Firms," and the "Practice Rules for Securities Law Business of Law Firms (Trial)," and based on facts that have occurred or existed prior to the issuance of this legal opinion. We have adhered to the principles of diligence and good faith, conducted thorough verification and validation, and ensured that the facts determined in this legal opinion are true, accurate, and complete, and that the opinions expressed are legal, accurate, and accurate, without any false records, misleading statements, or material omissions, and we bear corresponding legal responsibilities.
This legal opinion is for the purpose of witnessing the legality of the relevant matters of the Company's Meeting only and shall not be used for any other purpose.
Our lawyers, in accordance with legal requirements, professional standards, ethical norms, and the spirit of diligence and responsibility recognized by the legal profession, have verified and validated the relevant documents and facts provided by the Company, and hereby issue the legal opinion as follows:
I. Convening and Holding Procedures of the Meeting
The Meeting was convened in accordance with the resolution of the sixth board of directors' sixth meeting held by the Company on April 24, 2026, which deliberated and approved the "Proposal on Convening the 2025 Annual General Meeting of the Company."
On April 25, 2026, the Company published the "Notice of PuniTesting Group Co., Ltd. on Convening the 2025 Annual General Meeting" (hereinafter referred to as the "Meeting Notice") on the Juchao Information website. The "Meeting Notice" specified the convener, on-site meeting time, online voting time, meeting format, on-site meeting location, matters to be deliberated at the meeting, equity registration date, attendees, and registration matters.
The Meeting was held by combining on-site voting and online voting, including:
- The on-site meeting was held at 15:00 on May 18, 2026, in the conference room of PuniTesting Building, Building 1, No. 66 Jinda Road, Zhongguancun Environmental Protection Technology Demonstration Park, Haidian District, Beijing.
- The online voting time through the Shenzhen Stock Exchange trading system was: May 18, 2026, from 9:15-9:25, 9:30-11:30, and 13:00-15:00; the online voting time through the Shenzhen Stock Exchange Internet voting system was: May 18, 2026, from 9:15-15:00.