Deheng Shanghai Law Office
Legal Opinion on Jiangsu HengHui Security Group Co., Ltd.'s 2026 Second Extraordinary General Meeting
Deheng Ref. No. 02G20210303
To: Jiangsu HengHui Security Group Co., Ltd.
Jiangsu HengHui Security Group Co., Ltd. (hereinafter referred to as the "Company") convened its 2026 Second Extraordinary General Meeting (hereinafter referred to as the "Meeting") on June 22, 2026 (Monday). Deheng Shanghai Law Office (hereinafter referred to as "Deheng" or "the Firm") was entrusted by the Company to appoint lawyer Liu Zhenyi and lawyer Jin Ying (hereinafter referred to as "Deheng Lawyers") to attend the Meeting. In accordance with the "Securities Law of the People's Republic of China" (hereinafter referred to as the "Securities Law"), the "Company Law of the People's Republic of China" (hereinafter referred to as the "Company Law"), the "Rules for Shareholders' Meetings of Listed Companies" issued by the China Securities Regulatory Commission (hereinafter referred to as the "Shareholders' Meeting Rules"), and the "Articles of Association of Jiangsu HengHui Security Group Co., Ltd." (hereinafter referred to as the "Articles of Association"), Deheng Lawyers attended the Meeting to witness the convening and holding procedures, the qualifications of attendees, the voting procedures, and other related matters, and to issue this legal opinion.
To issue this legal opinion, Deheng Lawyers attended the Meeting and reviewed the following documents provided by the Company, including but not limited to:
(I) The Articles of Association; (II) The "Shareholders' Meeting Procedures of Jiangsu HengHui Security Group Co., Ltd."; (III) The resolution of the 26th meeting of the third board of directors of the Company; (IV) The "Notice of Jiangsu HengHui Security Group Co., Ltd. on Convening the 2026 Second Extraordinary General Meeting" (hereinafter referred to as the "Notice of the Meeting") published by the Company on the CNINFO website (http://www.cninfo.com.cn) on June 4, 2026; (V) On-site attendance registration records and supporting documents of shareholders attending the Meeting; (VI) Supporting documents for the voting results of shareholders at the Meeting; (VII) Other meeting documents for this Meeting.
Deheng Lawyers are hereby assured that the Company has provided all materials that Deheng Lawyers deem necessary for issuing this legal opinion. The original materials, copies, and duplicates provided, as well as oral statements, are all true, accurate, and complete. Copies and duplicates are consistent with the original materials.
In this legal opinion, Deheng Lawyers, in accordance with the "Shareholders' Meeting Rules" and the Company's requirements, will only express opinions on whether the convening and holding procedures of the Meeting comply with the relevant provisions of laws, administrative regulations, the "Company Law," and the "Shareholders' Meeting Rules," and whether the qualifications of the attendees and the convener are legal and valid, and whether the voting procedures and results are legal and valid. This opinion does not express any opinion on the content of the proposals reviewed at the Meeting or the truthfulness and accuracy of the facts or data stated in these proposals.
Deheng and Deheng Lawyers, in accordance with the "Securities Law," the "Administrative Measures for Securities Legal Business of Law Firms," the "Practice Rules for Securities Legal Business of Law Firms (Trial)," and other relevant regulations, as well as the facts that have occurred or existed as of the date of issuance of this legal opinion, have diligently performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough investigations and verifications, and ensured that the facts determined in this legal opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, and that there are no false records, misleading statements, or major omissions, and are willing to bear corresponding legal responsibilities.