Shanghai Allbright Law Offices (Qingdao)
Legal Opinion on Qingdao Guanzhong Ecological Co., Ltd.'s Convertible Bond Put Option
To: Qingdao Guanzhong Ecological Co., Ltd.
Shanghai Allbright Law Offices (Qingdao) (hereinafter referred to as the "Firm") has been retained by Qingdao Guanzhong Ecological Co., Ltd. (hereinafter referred to as the "Company" or "Issuer") to provide this Legal Opinion regarding the put option related to the Company's issuance of convertible corporate bonds to non-specific targets (hereinafter referred to as the "Current Put Option"). This opinion is based on the Company Law of the People's Republic of China, the Securities Law of the People's Republic of China, the Shenzhen Stock Exchange GEM Stock Listing Rules, the Measures for the Administration of Convertible Corporate Bonds, the Shenzhen Stock Exchange Listed Company Self-Regulatory Guidelines No. 15 - Convertible Corporate Bonds, and other relevant laws, regulations, rules, and normative documents, as well as the provisions of the Prospectus for the Issuance of Convertible Corporate Bonds to Non-specific Targets by Qingdao Guanzhong Ecological Co., Ltd. (hereinafter referred to as the "Prospectus").