Beijing Zhong Lun Law Firm
Supplementary Legal Opinion (I) on the Issuance of Shares to Specific Targets by Shanghai Xiangfeng Hua Technology Co., Ltd.
To: Shanghai Xiangfeng Hua Technology Co., Ltd.
Beijing Zhong Lun Law Firm (hereinafter referred to as "this Firm") was engaged by Shanghai Xiangfeng Hua Technology Co., Ltd. (hereinafter referred to as the "Issuer" or the "Company") to serve as special legal counsel for the Issuer's issuance of shares to specific targets (hereinafter referred to as the "Issuance").
This Firm has previously issued the "Attorney's Work Report of Beijing Zhong Lun Law Firm on the Issuance of Shares to Specific Targets by Shanghai Xiangfeng Hua Technology Co., Ltd." (hereinafter referred to as the "Attorney's Work Report") and the "Legal Opinion of Beijing Zhong Lun Law Firm on the Issuance of Shares to Specific Targets by Shanghai Xiangfeng Hua Technology Co., Ltd." (hereinafter referred to as the "Legal Opinion").
In view of the "Inquiry Letter on the Application of Shanghai Xiangfeng Hua Technology Co., Ltd. for Issuance of Shares to Specific Targets" (Inquiry Letter [2026] No. 020064) (hereinafter referred to as the "Inquiry Letter") issued by the Shenzhen Stock Exchange on July 20, 2026, this Firm hereby issues this "Supplementary Legal Opinion (I) on the Issuance of Shares to Specific Targets by Shanghai Xiangfeng Hua Technology Co., Ltd." (hereinafter referred to as this "Supplementary Legal Opinion") regarding the matters involved in the Inquiry Letter.
This Supplementary Legal Opinion serves as a supplement to the Legal Opinion and the Attorney's Work Report; in case of any inconsistency, this Supplementary Legal Opinion shall prevail. The statements made by this Firm's attorneys in the Legal Opinion and the Attorney's Work Report apply to this Supplementary Legal Opinion.
Unless otherwise specified, the definitions of terms in this Supplementary Legal Opinion are consistent with those in the Legal Opinion and the Attorney's Work Report issued by this Firm for the Issuance. The statements in the Legal Opinion and the Attorney's Work Report also apply to this Supplementary Legal Opinion.
This Firm and its attorneys have not authorized any entity or individual to provide any interpretation or explanation of this Supplementary Legal Opinion.
This Supplementary Legal Opinion is intended solely for the Issuer's use in the Issuance and may not be used for any other purpose without the written consent of this Firm.
In accordance with the relevant provisions of the "Securities Law" and based on the business standards, ethical norms, and the spirit of diligence and due care generally accepted in the legal profession, this Firm's attorneys have conducted verification of the documents and facts related to the Issuer's Issuance and hereby issue this supplementary legal opinion as follows:
I. Question 1 of the "Inquiry Letter"