Beijing Dacheng Law Firm
Regarding Zhongjin Irradiation Co., Ltd.'s 2025 Private Placement of A Shares
Supplementary Legal Opinion (I)
To: Zhongjin Irradiation Co., Ltd.
Beijing Dacheng Law Firm is a law firm with Chinese legal practice qualifications, entrusted by the issuer to serve as the special legal advisor for the issuer's application for a private placement of A shares in 2025. This firm and the lawyers dispatched by this firm have issued the "Beijing Dacheng Law Firm's Legal Opinion on Zhongjin Irradiation Co., Ltd.'s 2025 Private Placement of A Shares" (hereinafter referred to as the "Legal Opinion"), the "Beijing Dacheng Law Firm's Lawyer's Work Report on Zhongjin Irradiation Co., Ltd.'s 2025 Private Placement of A Shares" (hereinafter referred to as the "Lawyer's Work Report"), and other necessary notarized opinions on June 25, 2026.
On July 17, 2026, the Shenzhen Stock Exchange issued the "Inquiry Letter Regarding Zhongjin Irradiation Co., Ltd.'s Application for Private Placement of Shares" (Inquiry Letter [2026] 020063) (hereinafter referred to as the "Inquiry Letter") to the issuer, requesting explanations, investigations, and opinions from the issuer and relevant intermediaries. This firm will now conduct investigations into the issues requiring the issuer's lawyers to investigate and provide clear opinions as requested by the "Inquiry Letter."
This firm and the lawyers dispatched by this firm, in accordance with the "Securities Law," "Company Law," "Measures for the Administration of Securities Legal Business of Law Firms," and "Practice Rules for Securities Legal Business of Law Firms (Trial)," and other relevant laws and regulations, and the relevant regulations of the China Securities Regulatory Commission, and based on the facts that have occurred or exist prior to the issuance date of this Supplementary Legal Opinion, and on the basis of the facts in the "Legal Opinion" and "Lawyer's Work Report," have conducted supplementary investigations into the relevant facts and materials involved in this Supplementary Legal Opinion in accordance with the generally accepted business standards, ethical norms, diligence, and good faith principles of the legal profession, ensuring that the facts determined in this Supplementary Legal Opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, without any false records, misleading statements, or significant omissions.
This Supplementary Legal Opinion is a supplement to the "Legal Opinion" and "Lawyer's Work Report" and constitutes an inseparable part of the "Legal Opinion" and "Lawyer's Work Report." The statements made by this firm in the "Legal Opinion" and "Lawyer's Work Report" apply to this Supplementary Legal Opinion; the terms, names, and abbreviations used in this Supplementary Legal Opinion have the same meanings as those in the "Legal Opinion" and "Lawyer's Work Report" issued by this firm, unless otherwise specified.
This Supplementary Legal Opinion is for the purpose of the issuer's current issuance only and shall not be used for any other purpose.
This firm agrees that this Supplementary Legal Opinion will be submitted as a necessary legal document for the issuer's current issuance along with other application materials for this issuance, and will be legally responsible for the legal opinion issued.
Based on the foregoing, this firm hereby issues the following supplementary legal opinion: