Beijing Global Law Office
Regarding Sanhe Tongfei Refrigeration Co., Ltd.'s Private Placement of Shares
Supplementary Legal Opinion (I)
GLO2026BJ(Law) No. 0456-1-1
To: Sanhe Tongfei Refrigeration Co., Ltd.
Beijing Global Law Office (hereinafter referred to as "the Firm") has been retained by Sanhe Tongfei Refrigeration Co., Ltd. (hereinafter referred to as "the Issuer" or "the Company") as its special legal counsel for the Company's private placement of shares to specific objects (hereinafter referred to as "the Offering"). The Firm has previously issued the "Beijing Global Law Office's Legal Opinion on Sanhe Tongfei Refrigeration Co., Ltd.'s Private Placement of Shares" (hereinafter referred to as the "Legal Opinion") and the "Beijing Global Law Office's Lawyer's Work Report on Sanhe Tongfei Refrigeration Co., Ltd.'s Private Placement of Shares" (hereinafter referred to as the "Lawyer's Work Report").
In view of the "Inquiry Letter on the Application Documents for the Offering of Shares to Specific Objects by Sanhe Tongfei Refrigeration Co., Ltd." (Shenzhen Stock Exchange Listing Review Center Inquiry Letter [2026] 020037) (hereinafter referred to as the "Inquiry Letter") issued by the Shenzhen Stock Exchange Listing Review Center, the Firm's lawyers have conducted further verification of the matters related to the aforementioned Inquiry Letter, made corresponding revisions, supplements, or further explanations to the content disclosed in the Firm's Lawyer's Work Report and Legal Opinion, and hereby issue this Supplementary Legal Opinion.
This Supplementary Legal Opinion supplements the Lawyer's Work Report and the Legal Opinion and forms an integral part thereof. The content of the Lawyer's Work Report and the Legal Opinion that has not been modified by this Supplementary Legal Opinion remains valid. The legal disclaimer in the Lawyer's Work Report and the Legal Opinion also applies to this Supplementary Legal Opinion. Unless otherwise specified, the relevant definitions in this Supplementary Legal Opinion are consistent with those in the Lawyer's Work Report and the Legal Opinion.
The Firm's lawyers agree to submit this Supplementary Legal Opinion as an indispensable legal document for the Issuer's Offering, along with other application materials, and shall bear the corresponding legal responsibility for the opinions issued by the Firm.
The Firm and its handling lawyers, in accordance with the "Securities Law," "Company Law," "Administrative Measures," "Listing Rules," "Administrative Measures for Securities Legal Business of Law Firms," and "Practice Rules for Securities Legal Business of Law Firms (Trial)," and based on facts that have occurred or existed prior to the issuance date of this Supplementary Legal Opinion, have strictly performed their statutory duties, adhered to the principles of diligence and good faith, conducted thorough verification, and ensured that the facts identified 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 material omissions, and shall bear corresponding legal responsibilities.
This Supplementary Legal Opinion is for the purpose of the Issuer's Offering only and shall not be used for any other purpose.
In accordance with the "Securities Law," "Company Law," and other relevant laws, regulations, and the China Securities Regulatory Commission's regulations, and in accordance with the generally accepted business standards, ethical norms, and the spirit of diligence and good faith of the legal profession, the Firm's lawyers hereby issue the following supplementary legal opinion:
I. Inquiry Letter, Question 2